Also known as: case-or-controversy requirement · Article III case or controversy · cases and controversies · justiciability requirement · Article III standing
Written by attorneys — see sources below.
A constitutional limit on federal judicial power that confines federal courts to actual disputes between adverse parties rather than hypothetical or abstract questions. The requirement demands a concrete and particularized injury in fact that is traceable to the defendant and redressable by a favorable judicial decision. Generalized grievances shared equally by all citizens fail to satisfy the limit even when Congress authorizes suit by statute.
Corinne Cho, a taxpayer in State A, sued federal officials alleging that a new statute authorizing expenditures violated the Appropriations Clause. She claimed only that the government had failed to follow the law and that all citizens shared her interest in lawful spending. The court dismissed the action because the asserted injury was not particularized to Cho.
Cody Callahan sued his employer in federal court under a federal wage statute for unpaid overtime on a single bridge project. The employer then asserted state-law counterclaims for defective workmanship against Callahan and a new engineering firm that had inspected the same project. The district court exercised authority over the state claims because they arose from the identical construction sequence and operative facts.
Cade Carpenter downloaded a mobile app that displayed more digits of his frequent-flyer number than permitted by federal privacy rules. He sued the app developer alleging only the statutory breach and identified no account access, identity theft, or financial loss. The court dismissed the complaint for lack of a concrete injury in fact.
Christopher Collins, a citizen of State A, filed a diversity action against a State B corporation seeking $90,000 in lost profits from a terminated supply contract. Two additional suppliers domiciled in State C asserted smaller state-law claims arising from the same termination decision under the identical prime contract. The district court exercised supplemental jurisdiction over the additional claims once the anchor plaintiff satisfied the amount-in-controversy requirement and complete diversity existed.
In 1991, about 10,000 Exxon dealers filed a class-action suit against the Exxon Corporation in the United States District Court for the Northern District of Florida. They alleged an intentional and systematic scheme by which they were overcharged for fuel purchased from Exxon. The plaintiffs invoked the District Court's diversity jurisdiction under 28 U.S.C. § 1332(a). Each dealer's claim was for slightly less than the $75,000 jurisdictional minimum. After a unanimous jury verdict in favor of the plaintiffs, the District Court certified the case for interlocutory review on the question of supplemental jurisdiction over class members who did not meet the jurisdictional minimum. In a separate action, a 9-year-old girl sued Star-Kist in a diversity action in the United States District Court for the District of Puerto Rico. She sought damages for unusually severe injuries she received when she sliced her finger on a tuna can. Her family joined in the suit seeking damages for emotional distress and medical expenses. The District Court granted summary judgment to Star-Kist, finding that none of the plaintiffs met the minimum amount-in-controversy requirement. The Court of Appeals for the Eleventh Circuit upheld the District Court's extension of supplemental jurisdiction to the class members who did not meet the amount requirement. The Court of Appeals for the First Circuit ruled that the injured girl, but not her family members, had made allegations of damages in the requisite amount. It further held that section 1367 authorizes supplemental jurisdiction only when the district court has original jurisdiction over the action. In a diversity case, original jurisdiction is lacking if one plaintiff fails to satisfy the amount-in-controversy requirement. The Supreme Court granted certiorari to resolve the conflict among the Courts of Appeals. The cases were consolidated before the Supreme Court.
Chloe Chen sued a manufacturer for alleged environmental violations under a citizen-suit provision and obtained a favorable district-court judgment. While the appeal was pending the manufacturer ceased the challenged conduct and entered a consent decree with the government. The appellate court dismissed the case because the plaintiff no longer satisfied the redressability element of the case-or-controversy requirement.
Citizens for a Better Environment, an association of individuals interested in environmental protection, sued Steel Company, a small manufacturing company located in Chicago, alleging that Steel Company had failed since 1988 to complete and submit the annual hazardous-chemical inventory forms and toxic-chemical release forms required by the Emergency Planning and Community Right-To-Know Act of 1986. The forms must list the name and location of the facility, the name and quantity of each specified chemical on hand, the waste-disposal method employed, and the annual quantity of toxic chemicals released into each environmental medium, with inventory forms due each March 1 and release forms due each July 1. In 1995 the association sent the required 60-day notice to Steel Company, the EPA Administrator, and Illinois authorities, accurately alleging that Steel Company had never filed the required forms. Upon receiving the notice, Steel Company filed all of the overdue forms with the appropriate agencies. The EPA took no enforcement action, and after the waiting period expired the association filed its complaint in federal district court. The complaint, brought on behalf of the association and its members, sought a declaratory judgment that Steel Company had violated EPCRA, authorization for periodic inspections of Steel Company's facility and records at Steel Company's expense, an order compelling Steel Company to provide the association with copies of all compliance reports submitted to the EPA, civil penalties of $25,000 per day for each violation, and an award of the association's investigation and litigation costs including reasonable attorney and expert witness fees. The district court agreed with Steel Company on both points and dismissed the complaint. The United States Court of Appeals for the Seventh Circuit reversed, and the Supreme Court granted certiorari to resolve a conflict with the Sixth Circuit's decision in a factually indistinguishable case.
Claire Campbell, the attorney general of State A, sued a federal agency for failing to regulate greenhouse-gas emissions from new motor vehicles. The state alleged that rising sea levels threatened its coastal property and that the agency’s inaction caused that injury. The court held that the state satisfied the injury, causation, and redressability elements of the case-or-controversy requirement.
In October 1999, nineteen private organizations filed a rulemaking petition with the EPA requesting regulation of greenhouse gas emissions from new motor vehicles under section 202 of the Clean Air Act. The petition asserted that carbon dioxide and other gases were heat-trapping greenhouse gases that had accelerated climate change, with carbon dioxide as the most important contributor according to the IPCC's 1995 report. The EPA received more than fifty thousand comments after requesting public input in 2001. A National Research Council report from 2001, prepared at the White House's request, stated that greenhouse gases from human activities were causing surface air temperatures to rise. On September 8, 2003, the EPA denied the petition on two grounds: the Clean Air Act did not authorize regulation of greenhouse gases from motor vehicles, and even assuming authority, the agency would not regulate due to scientific uncertainty about causation and concerns that regulation would conflict with the President's comprehensive approach involving voluntary programs and international negotiations. The denial order referenced Congress's decision in 1990 not to enact binding emissions limitations and the political history of climate change issues. Petitioners including the Commonwealth of Massachusetts and other states and private organizations then sought review in the United States Court of Appeals for the District of Columbia Circuit. The D.C. Circuit denied the petition for review in 2005. The Supreme Court granted certiorari in 2006 to address the issues raised by the denial. Massachusetts submitted affidavits showing that global sea levels rose 10 to 20 centimeters over the 20th century, already causing loss of coastal land owned by the Commonwealth, with projections of further inundation by 2100. The United States transportation sector alone emitted more than 1.7 billion metric tons of carbon dioxide in 1999, accounting for over 6 percent of worldwide emissions.
Article III demands an injury in fact that is both particularized and concrete. A bare statutory violation without any actual or threatened harm to the plaintiff is insufficient. Generalized grievances shared equally by all citizens likewise fail to confer standing.
Once a district court has original jurisdiction over one claim, it may hear additional claims that form part of the same case or controversy under Article III. The additional claims must share a common nucleus of operative fact with the anchor claim, and the exercise of jurisdiction must not violate statutory limitations such as those in 28 U.S.C. § 1367(b).
…adequate safeguards against abuse), vacated, Lee v. Oregon , 107 F. 3d 1382 (CA9 1997) (concluding that plaintiffs lacked Article III standing). Lee , of course, is not before us, any more than it was before the Court of Appeals below, and we offer no opinion as to the validity of the Lee courts' reasoning. In Vacco v.…
…No. 45, p. 292 (C. Rossiter ed. 1961) (J. Madison). The judicial authority to determine the constitutionality of laws, in cases and controversies, is based on the premise that the "powers of the legislature are defined and limited; and that those limits may not be mistaken, or forgotten, the constitution is written." Marbury v.…
…all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution. Such supplemental jurisdiction shall include claims that involve the joinder or intervention of additional parties.” The statute’s grant of supplemental…
…of the Constitution limits the "judicial power" to the resolution of "cases" and "controversies
…paint with a much broader brush than may this Court, which must confine itself to the judicial function of deciding individual cases and controversies
No. Congress may create statutory rights whose violation can satisfy the injury requirement, but it cannot eliminate the constitutional need for a concrete and particularized injury, causation, and redressability. A plaintiff must still demonstrate an actual injury even when a citizen-suit provision exists.
Yes. The case-or-controversy requirement applies at every stage, including appeal. If intervening events remove the plaintiff’s concrete stake, the action becomes nonjusticiable even if standing existed when the complaint was filed.