Also known as: cases where a state is a party · state party cases · original jurisdiction · state as party
Written by attorneys — see sources below.
A constitutional category of controversies over which the Supreme Court possesses original jurisdiction when a state appears as a party to the suit.
State X and State Y disagreed over the precise location of their shared river boundary after a flood shifted the channel. State X filed an original action in the Supreme Court seeking a decree establishing the boundary line. The Court accepted the case for original jurisdiction because a state was a party to the controversy.
Clifford Cox, a state employee, sued State Z in federal district court alleging violations of federal wage and hour laws. The court exercised federal-question jurisdiction over the claim because the action arose under federal statutes even though a state was the defendant.
Cascade Manufacturing sued State W in federal court for breach of a federal grant contract and added state-law claims for additional payments arising from the same project. The court exercised supplemental jurisdiction over the state claims because they formed part of the same case or controversy as the federal claim.
Charles Cunningham sued State V in state court under a federal civil rights statute. State V removed the action to federal district court, which accepted jurisdiction because the complaint presented a federal question and a state was the defendant.
Cameron Cruz sued State U in state court for overtime wages under federal law. State U moved to dismiss on sovereign immunity grounds, arguing that Congress had not validly abrogated its immunity from private suits in its own courts.
In 1992, petitioners, a group of probation officers, filed suit against their employer, the State of Maine, in the United States District Court for the District of Maine. The officers alleged the State had violated the overtime provisions of the Fair Labor Standards Act of 1938 and sought compensation and liquidated damages. While the suit was pending, the Supreme Court decided Seminole Tribe of Florida v. Florida in 1996. Upon consideration of that decision, the District Court dismissed petitioners' action, and the Court of Appeals affirmed. Petitioners then filed the same action in state court. The state trial court dismissed the suit on the basis of sovereign immunity, and the Maine Supreme Judicial Court affirmed in 1998. The Maine Supreme Judicial Court's decision conflicted with the decision of the Supreme Court of Arkansas in Jacoby v. Arkansas Department of Education. In light of the importance of the question presented and the conflict between the courts, the Supreme Court granted certiorari in 1998. The United States intervened as a petitioner to defend the statute. Petitioners are a group of probation officers who alleged violations of federal overtime requirements by their state employer. The procedural path moved from federal district court through dismissal after Seminole Tribe, to refiling in Maine state court, dismissal there, affirmance by the Maine Supreme Judicial Court, and finally review by the United States Supreme Court.
View caseChristine Castro and other plaintiffs sued State T in federal court asserting state-law claims that individually fell below the jurisdictional threshold. The court permitted aggregation of the claims to meet the amount-in-controversy requirement because at least one claim satisfied the statutory minimum.
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.
View caseArticle III grants the Supreme Court original jurisdiction in all cases in which a state is a party. This jurisdiction is self-executing and applies directly to controversies between two or more states or between a state and citizens of another state.
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States retain immunity from private suits in their own courts absent consent. This immunity is inherent in sovereignty and prevents actions by individuals against a state without its permission.
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Yes. Once a district court has original jurisdiction over a claim against a state, it may exercise supplemental jurisdiction over related state-law claims that form part of the same case or controversy.
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…of the District Courts. Congress has exercised that power in 28 U. S. C. § 1343 (3): "The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person . . . [t]o redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any…