Subject Matter Jurisdiction Terms Flashcards
Subject Matter Jurisdiction
Power of the court to hear/decide the legal issues in a case, governed by article 3 of the constitution
- vs. personal jurisdiction = power over people (parties)
State Courts and their jurisdiction over federal law claims
(1) have general subject matter jurisdiction unless there’s a statute of carves out certain claims
(2) need complete diversity between parties: determined by domicile and $75,000 amount threshold
Jurisdiction over federal law claims:
- During constitutional ratification, they existed no federal courts state court, and Supreme Court were the only courts to clear up inconsistencies
- State courts do most of the work
- General presumption that state courts can hear every kind of case involving federal law and federal government interests and will do as good of a job adjudicating
Federal Courts and their jurisdiction over state court
- lack of subject jurisdiction, unless there’s a certain statute given to it
- Everyone is subject to the power of two sovereign: federal and state
Jurisdiction over state court:
- State courts have to hear federal law claims if state courts have similar laws
- occasional gaps between subject matter jurisdiction where you can invoke from Judiciary Act between two states
- Worried state courts won’t be impartial/ unbiased against statute
The Rule of Complete Diversity
Strawbridge v. Curtiss determined that all D’s must be completely diverse from all Ps in order to obtain federal jurisdiction based on diversity of citizenship
- Rationale: there would be a disproportioned state interest if there are multiple Ps and D’s from the same state
- even when Strawbridge is not met, can expand diversity jurisdiction through minimal diversity = interpleader action with $500 amount-in-controversy requirement where at least one claimant is a citizen of a state state different from the other claimants
Diversity Jurisdiction Debate
Arguments FOR diversity:
- biased against out-of-state litigants—need this for investors to enter into markets in different states (under the belief that will receive fair treatment)
- encourages competition between state and federal court systems —> to judicial reform
- Encourage legal improvement with federal system, “cross-pollination” of ideas to become alert to issues across jurisdictional boundaries
Arguments AGAINST:
- indirect federal interference
- Docket congestion channeling state law disputes to federal judges, making federal disposition wasteful andinappropriate
- supports gamesmanship that has little to do with constitutional justification for authorizing a federal forum
Determining Citizenship for people, corporations/associations, and Unincorporated Associations
People:
- Domicile= place of “true, fixed and permanent home and principal establishment…changed by (a) taking up residence in a different domicile with (b) the intention to remain there
- Whenever you cannot establish an intent to remain, defaults to your former domicile
Corporations and Associations
Different rules apply—unlike a natural person, a corporation may have multiple states of citizenship
- it’s a citizen of every state and foreign state It’s incorporated and the state or foreign state of principal place of business three tests:
- ”nerve-center” test = located citizenship in the state in which corporate decision-making an overall control takes place (usually HQ)
- ”corporate activities” or “operating assets” test = located citizenship and state, and which corporation has its production or service activities (where most of the corporate activities)
- ”total activity” test= located citizenship in light of all facts and circumstances (ex: executives are New York, but all the factories workers in Ohio, principal place should be Ohio)
Unincorporated Associations = not treated as an entity, but rather take on citizenship of each and every one of the associations’ members, where the partnership is domiciled
SMJ Article 3 section 2 of Constitution, 1332
Extends to the following and only if Congress has enacted a statute conferring jurisdiction over such case/controversy:
- Between citizens of different states, ruled by 1332 which requires:
- Diversity of parties (all parties across the isle must be diverse)
- An amount of over $75k
- Between a State or Citizens therefor
- Foreign States, Citizens, or Subjects
- Supplemental and Removal
Aggregation
- single P sues single D, P CAN aggregate value of all its claims to meet amount-in-controversy requirement. claims don’t need to share common questions of law or fact
- multiple Ps sue single D. CAN aggregate claims to meet amount-in-controversy requirement only if claims are common or indivisible (does not mean identical)
- multiple Ps joint and severable, Ps CANNOT aggregate them to meet jurisdictional amount
Federal Question Jurisdiction, Constitution Article 3, Section 2 and 1331
Traditional power shall extend all cases, in law and equity, arising under this constitution, the laws of the US, and treaties made, or which shall be made, under their authority
1331: federal question the district court shall have original jurisdiction of all civil actions arising under the constitution laws or treaties of the US. narrower than Constitution
- difference between 1332 is that this refers to “civil actions” which is narrower than “cases”
Holmes Rule (or Creation Test)
- Civil actions “arise under” the law that creates the cause of action (American Well Works, TB Harms)
- Strong federal interest where no federal cause of action?? (Smith/Moore)
- Express vs. implied cause of action (Merrell Dow)
Grable Test
- Federal issue must be CONTESTED
- Federal issue must be SUBSTANTIAL, AND
- Federal SMJ must be “consistent with congressional judgment about the sound division of labor between state and federal courts
Steps of Federal Jurisdiction Inquiry
- Is there federal cause of action? (Holmes Test)
- if yes, go to #2, if no #3 - Shoshone mining case?
- Grable Test
SMJ over Supplemental Claims
Federal System Values
Civil Actions in Federal Courts
FSV:
- opening courthouse doors to let claims in and decide them on the merits
- Want to resolve the entire dispute all at the same time and efficiently
CAiF
- These values are intention with the principal that federal courts have limited jurisdiction (power is the exception, not the rule)
Supplemental Jurisdiction Statute 28 USC 1367(a)
pendant claims and parties
- diversity or federal question cases
-
”same case or controversy” standard (Gibbs)
- does claimed derive from a “common nucleus of operative fact” if yes —> court sees claims could be resolved in the same court
- including “claims that involve the joinder or intervention of additional parties (Rule 20 Joinder, Rule 24 Intervenors)
Supplemental Jurisdiction Statute 28 USC 1367(b)
supplemental jurisdiction in diversity cases
- “same case or controversy” test, like 1367(a)
- applies to claims against later-added parties (Rule 14, party-complaint rule)
- no more “ancillary jurisdiction” as separate concept
-
no supplemental jurisdiction that would destroy diversity (Owen equipment)
- need independent diversity on both sides of “v”
- needs to relate to original complaint
