Also known as: federal question cases · federal-question case · federal question jurisdiction
Written by attorneys — see sources below.
A basis for federal subject-matter jurisdiction that exists when the plaintiff's well-pleaded complaint asserts a right to relief created by the Constitution or laws of the United States. The inquiry examines only the face of the complaint and does not turn on anticipated defenses, counterclaims, or the absence of an express statutory remedy.
Farid Farahani sued a federal agency in district court alleging that agents violated his Fourth and Fifth Amendment rights during a warrantless search of his office and seizure of servers. The complaint sought damages directly under the Constitution even though no statute expressly authorized such relief. The court determined that the claim arose under federal law because the complaint pleaded a right to relief created by the Constitution.
Fatima Flores filed a state-court breach-of-contract action against Fisher Foods alleging that the company failed to pay amounts due under a supply agreement. The complaint mentioned that Fisher Foods would likely defend by claiming federal regulations capped the payments owed. Fisher Foods removed the case to federal court on the basis of that anticipated defense. The district court held that federal question jurisdiction was absent because the complaint asserted only a state-law claim.
Flora Ford sued Frostline Textiles in state court for nuisance and trespass arising from chemical runoff that damaged her property. The complaint devoted several paragraphs to describing how Frostline would defend by citing compliance with federal environmental permits and arguing preemption. Frostline removed the action asserting federal question jurisdiction. The federal court remanded the case because the complaint pleaded only state-law causes of action.
Felix Franco brought a federal copyright-infringement claim in district court against Fusion Power for unauthorized use of protected software code. In the same complaint he added a state-law unfair-competition claim arising from the identical course of copying and distribution. The court exercised supplemental jurisdiction over the state claim because both claims derived from a common nucleus of operative fact.
Frank Fisher, a citizen of State A, sued Foxfire Biotech, a citizen of State B, in federal court asserting a federal antitrust claim and joined an additional state-law contract claim against the same defendant. The amount in controversy for the contract claim was below the diversity threshold. The court exercised supplemental jurisdiction over the contract claim because it formed part of the same case or controversy as the federal claim.
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.
Finn Fletcher sued the State of Florida in federal court seeking damages for alleged violations of federal environmental statutes arising from state permitting decisions. The complaint asserted that the claims arose under federal law. The court dismissed the action because Eleventh Amendment immunity barred the suit against the unconsenting state even though federal issues were presented.
In 1988 Congress enacted the Indian Gaming Regulatory Act to provide a statutory basis for the operation of gaming by Indian tribes. The Act divides gaming on Indian lands into three classes. Class III gaming includes slot machines, casino games, banking card games, dog racing, and lotteries. Such gaming is lawful only when conducted in conformance with a Tribal-State compact entered into by the Indian tribe and the State. The Act imposes upon the States a duty to negotiate in good faith with an Indian tribe toward the formation of such a compact. It authorizes a tribe to bring suit in federal court against a State in order to compel performance of that duty. The Seminole Tribe of Florida requested that the State of Florida enter into negotiations for a compact governing class III gaming on the Tribe's lands. When the State refused to negotiate, the Tribe filed suit in September 1991 in the United States District Court for the Northern District of Florida against the State and its Governor, Lawton Chiles. The Tribe invoked jurisdiction under 25 U.S.C. § 2710(d)(7)(A), as well as 28 U.S.C. §§ 1331 and 1362. It alleged that respondents had refused to enter into any negotiation for inclusion of certain gaming activities in a tribal-state compact, thereby violating the requirement of good faith negotiation contained in § 2710(d)(3). The State moved to dismiss the complaint, arguing that the suit violated the State's sovereign immunity from suit in federal court. The District Court denied the motion. On interlocutory appeal, the Court of Appeals for the Eleventh Circuit reversed. It held that the Eleventh Amendment barred the Tribe's suit against the State and that the doctrine of Ex parte Young did not permit a suit against the Governor to enforce the statutory duty. The Eleventh Circuit remanded with directions to dismiss the suit. The Supreme Court granted certiorari in 1995 to consider whether the Eleventh Amendment prevents Congress from authorizing suits by Indian tribes against States for prospective injunctive relief to enforce legislation enacted pursuant to the Indian Commerce Clause and whether the Ex parte Young doctrine permits suits against a State's Governor for such relief.
No. A plaintiff may invoke federal question jurisdiction by alleging a right to relief directly under the Constitution or federal statutes even when Congress has not created an express damages remedy. The jurisdictional inquiry focuses on whether the complaint asserts a nonfrivolous federal right, not on the existence of a statutory remedial scheme.
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…restore the pre- Finley understandings of the authorization for and limits on other forms of supplemental jurisdiction. In federal question cases, it broadly authorizes the district courts to exercise supplemental jurisdiction over additional claims, including claims involving the joinder of additional parties. In diversity cases,…
…were subject to reversal on appeal whenever it would alter the rule of claim preclusion applied by the State in which the federal court sits. No one suggests that this is the rule, and we are aware of no
…scope of the state claim implicates the federal doctrine of pre-emption; while this interrelationship does not create statutory federal question jurisdiction
…cases brought by a citizen of another State, its express terms pose no bar to a federal court assuming
…In none of the statutes enacted since that time have saving-clause cases been made removable. : Of course
No. The well-pleaded complaint rule requires that the federal issue appear on the face of the plaintiff's own cause of action. Neither a defense raised in the answer nor a counterclaim asserting federal law can supply arising-under jurisdiction.
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No. References in the complaint to federal law that merely anticipate what the defendant will argue as a defense do not satisfy the well-pleaded complaint rule. The court looks only to the elements the plaintiff must prove to establish the claim.
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A federal court may hear state-law claims that derive from a common nucleus of operative fact with the federal claim such that the plaintiff would ordinarily be expected to try them together. The exercise of supplemental jurisdiction remains discretionary and may be declined when state issues predominate or other factors counsel against it.
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