Study Notes on Federal Courts and Jurisdiction

Federal Courts and Limited Jurisdiction

  • Federal courts have limited jurisdiction, meaning they cannot hear just any case.
  • Jurisdiction must be granted through constitutional or statutory authority.

Sources of Jurisdiction

  • 28 U.S.C. § 1331: Federal question jurisdiction.
  • 28 U.S.C. § 1332: Diversity of citizenship jurisdiction.
  • 28 U.S.C. § 1367: Supplemental jurisdiction.
  • These statutes are crucial for understanding subject matter jurisdiction, especially in civil procedure and bar exams.

Determining Subject Matter Jurisdiction

  • The first step is to determine whether a court has subject matter jurisdiction over a claim.

Questions to Consider

  1. Is the claim based on federal law?
    • If yes, original subject matter jurisdiction exists under 28 U.S.C. § 1331 due to the constitutional grant of authority under Article III, Section 2.
  2. If not based on federal law, is it a state law claim?
    • The court can only hear it under original subject matter jurisdiction if there is diversity under § 1332.
Well-Pleaded Complaint Rule
  • The claim must arise directly from federal law.
  • A defense based on federal law does not satisfy the requirements, as illustrated by the L & N Railroad v. Motley case.
Complete Diversity of Citizenship
  • Jurisdiction under § 1332 requires complete diversity between the parties.
  • Key Point: No plaintiff can be from the same state as any defendant.
    • Example: You may have multiple plaintiffs from Virginia as long as no defendant is from Virginia.

Determining Citizenship of Parties

  • For Natural Persons: Citizenship is determined by domicile (presence + intent to stay).
  • Corporations:
    • Citizenship includes the state where incorporated and the state of their principal place of business (nerve center).
  • Unincorporated Associations (e.g., LLCs, partnerships):
    • Citizenship is that of every member (owner), not merely employees.
Estates of Decedents
  • Generally handled in state court unless a situation arises involving a claim exceeding $75,000 and diversity of citizenship, e.g., state law negligence claims resulting from a decedent's estate.
  • The citizenship of the estate is that of the decedent at the time of death.

Amount in Controversy under § 1332

  • To pursue a case in federal court under § 1332, the amount in controversy must exceed $75,000.
  • Exclusions: Court costs and interest are excluded; attorney's fees may be included if allowed by statute or contract.
  • Aggregation of Claims:
    • A single plaintiff may aggregate claims against a defendant; multiple parties cannot aggregate separate claims against a defendant.

Subject Matter Jurisdiction Check for Claims

  • Each claim in an action must be examined for subject matter jurisdiction individually.
  • If original subject matter jurisdiction is absent, supplemental jurisdiction under 28 U.S.C. § 1367 may apply, provided there is an anchor claim with original jurisdiction.

Supplemental Jurisdiction Framework (28 U.S.C. § 1367)

Overview

  • Can be asserted if a claim is related to the anchor claim that has original jurisdiction.
  • Related claims must form part of the same case or controversy or arise from a common nucleus of operative fact.
Example of Supplemental Jurisdiction
  • If a plaintiff sues under federal law (anchor claim) and has additional state law claims that stem from the same facts, those state claims may be covered under supplemental jurisdiction.
Key Terminology
  • Anchor Claim: The claim that gives rise to federal jurisdiction.
  • Sprinkles: Additional related claims that may be heard alongside the anchor claim under supplemental jurisdiction.

Limitations of Supplemental Jurisdiction (28 U.S.C. § 1367(b))

  • This provision limits supplemental jurisdiction in diversity cases where the conditions of original jurisdiction under § 1332 are not met.
  • If the original claims were solely founded on § 1332, certain claims made by defendants against plaintiffs may not qualify for supplemental jurisdiction.

Practical Application and Examples

  • Client Case Scenarios:
    1. Claim against an employer for discrimination could be brought in either state or federal court due to concurrent jurisdiction unless the federal statute specifies otherwise.
    2. If a federal claim is made, the case can be filed in federal court under § 1331.
    3. If a state claim is made, and it arises from the same set of facts as a federal claim, supplemental jurisdiction could apply.
Implications of Successive Claims in Federal Court
  • If multiple claims arise from the same set of facts, and one has federal placement while others don't, those related claims can still serve under the umbrella of supplemental jurisdiction.

Conclusion

  • Always check for original subject matter jurisdiction first, then assess the claims related to it for potential supplemental jurisdiction under 28 U.S.C. § 1367.
  • Understanding the interplay of federal question jurisdiction and diversity jurisdiction will greatly aid in determining the appropriate jurisdictional claims in both practice and examination settings.