Also known as: jurisdictions of the cause · subject-matter jurisdiction · cause jurisdiction
Written by attorneys — see sources below.
A court's authority to adjudicate the subject matter of a particular dispute. The authority exists only when the claim falls within a statutory or constitutional grant of power to the court.
Judy Jacobs filed a state-law contract claim in federal district court against Jha Pharmaceuticals. After discovery revealed that both parties were citizens of the same state, the court examined the record on its own motion and dismissed the entire action.
Jamal Jefferson sued Jung BioTech in federal court asserting only state-law claims. Jung BioTech moved under Rule 12(b)(1) before answering, and the court granted the motion after determining that no federal question or diversity jurisdiction existed.
Jillian James sued Jaffe Securities in federal court. After the court dismissed the action for lack of subject-matter jurisdiction, James refiled the identical claim in state court. The state court treated the federal dismissal as without prejudice to the merits.
Petitioner Semtek International Inc. filed a complaint against respondent Lockheed Martin Corp. in California state court, alleging inducement of breach of contract and business torts. Respondent removed the case to the United States District Court for the Central District of California on the basis of diversity of citizenship. The district court dismissed petitioner’s claims as barred by California’s 2-year statute of limitations, adopting language suggested by respondent to dismiss the claims “in [their] entirety on the merits and with prejudice.” Petitioner appealed the dismissal to the Court of Appeals for the Ninth Circuit, which affirmed the district court’s order. Petitioner subsequently brought suit against respondent in the State Circuit Court for Baltimore City, Maryland, alleging the same causes of action. These claims were not time barred under Maryland’s 3-year statute of limitations. Respondent removed the action to the United States District Court for the District of Maryland on federal-question grounds, but that court remanded the case to state court. The Maryland state court granted respondent’s motion to dismiss on the ground of res judicata. Petitioner returned to the California federal court and the Ninth Circuit, moving unsuccessfully to amend the earlier order to indicate that the dismissal was not “on the merits.” Petitioner appealed the Maryland trial court’s order to the Maryland Court of Special Appeals. The Court of Special Appeals affirmed the dismissal. After the Maryland Court of Appeals declined to review the case, the Supreme Court granted certiorari.
View caseJordan Jenkins and several other plaintiffs joined a federal diversity action against Juarez Holdings. The court exercised supplemental jurisdiction over the additional plaintiffs whose individual claims fell below the amount-in-controversy threshold because one plaintiff satisfied the requirement.
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 caseJeanette Jensen and other environmental plaintiffs sued a federal agency alleging future harm to wildlife habitats. The court dismissed the complaint because the plaintiffs failed to show concrete, imminent injury traceable to the challenged regulation.
In 1973 Congress enacted the Endangered Species Act to protect species of animals against threats to their continuing existence caused by man. In 1978 the Fish and Wildlife Service and National Marine Fisheries Service issued a joint regulation interpreting section 7(a)(2) to require federal agencies to consult with the Secretary of the Interior on actions taken in foreign nations. In 1986 the Secretary promulgated a revised regulation that limited the consultation obligation to actions within the United States or on the high seas. Shortly after the 1986 regulation took effect, Defenders of Wildlife and other environmental organizations filed suit in the United States District Court for the District of Minnesota against the Secretary of the Interior. The complaint sought a declaratory judgment that the regulation was invalid as to its geographic scope and an injunction requiring the Secretary to promulgate a new regulation mandating consultation for foreign projects. The complaint alleged that the absence of consultation would increase the rate of extinction of endangered and threatened species. The complaint further alleged that some of the organizations' members observed these species both domestically and abroad. Respondents supported their allegations with affidavits from two members. Joyce Kelly stated that she had traveled to Egypt in 1986, observed the habitat of the endangered Nile crocodile, and intended to return. Kelly further stated that she would suffer harm from the United States role in the rehabilitation of the Aswan High Dam. Amy Skilbred stated that she had traveled to Sri Lanka in 1981, observed the habitat of endangered species including the Asian elephant and leopard at the site of the Mahaweli project funded by the Agency for International Development, and intended to return. Skilbred admitted she had no current plans to return because of a civil war. The District Court dismissed the complaint for lack of standing. The Court of Appeals for the Eighth Circuit reversed. On remand the District Court denied the Secretary's motion for summary judgment on standing. The District Court granted respondents' motion for summary judgment on the merits and enjoined the Secretary from applying the regulation to foreign countries. The Eighth Circuit affirmed. The Supreme Court granted certiorari.
View caseJavier Jimenez alleged that federal agents violated his Fourth Amendment rights during a search. The court recognized an implied damages action against the agents in their individual capacities even though no federal statute expressly created the remedy.
On the morning of November 26, 1965, agents of the Federal Bureau of Narcotics entered Webster Bivens's apartment in the Bronx. The agents broke open the door, handcuffed Bivens in front of his wife and young children, and thoroughly searched the apartment. They then transported Bivens to the federal courthouse in Brooklyn, where he was interrogated, booked, and subjected to a visual strip search. Several days later Bivens was released on his own recognizance, and he was never indicted or prosecuted for any offense. Bivens filed suit in the United States District Court for the Eastern District of New York against the six agents in their individual capacities. His complaint sought fifteen thousand dollars in damages from each agent and alleged that the arrest and search were effected without a warrant, that unreasonable force was employed, and that the arrest was made without probable cause. Bivens claimed to have suffered great humiliation, embarrassment, and mental suffering as a result of the agents' conduct. The District Court dismissed the complaint on the ground that it failed to state a cause of action. The United States Court of Appeals for the Second Circuit affirmed the dismissal. The Supreme Court of the United States granted certiorari to review the judgment.
View caseA federal court must dismiss an action at any time it determines that subject-matter jurisdiction is absent, including after discovery or on appeal.
Yes. A party may assert lack of subject-matter jurisdiction by pre-answer motion, and the defense is never waived.
A dismissal for lack of subject-matter jurisdiction does not operate as an adjudication on the merits and therefore does not bar a subsequent action on the same claim.
…to provide the respondent with a pretermination hearing. The Court of Appeals affirmed. Held: 1. The District Court had subject-matter jurisdiction over the action under 42 U.S.C. § 405(g). Pp. 324-332. 2. The procedures for review and termination of disability benefits under the Social Security Act do not violate the Due Process…