Also known as: ratione materiae jurisdiction · jurisdictio ratione materiae · subject-matter jurisdiction · jurisdiction by reason of the matter
Written by attorneys — see sources below.
A court's power to hear and decide cases involving a particular category of legal claims or subject matter. This power is determined by constitutional or statutory grants that allocate authority over specified types of disputes.
Joy Jiang sues Juarez Holdings in federal court for breach of a supply contract. After discovery closes and a summary judgment motion is fully briefed, the court notices that the amount in controversy is only $60,000. The court dismisses the entire action.
Jennifer Jackson files a federal complaint against Jackson Mutual alleging only state-law claims and seeking $40,000. The insurer moves under Rule 12(b)(1) to dismiss. The court grants the motion and terminates the case.
Judy Jacobs, a California policyholder, sues several foreign insurers in federal court over an alleged global conspiracy affecting U.S. reinsurance markets. The insurers argue the court lacks authority over the foreign conduct. The court retains the claims that directly affect American commerce.
In the late 1970s, ISO, an association of approximately 1,400 domestic property and casualty insurers that serves as the almost exclusive source of support services for CGL insurance in the United States, began revising its 1973 standard CGL policy form. The 1973 form provided occurrence-based coverage for sudden and accidental pollution and did not cap defense costs. Primary insurers including Hartford Fire Insurance Company, Allstate Insurance Company, Aetna Casualty and Surety Company, and CIGNA Corporation sought four changes: a shift to claims-made coverage with a retroactive date, elimination of pollution coverage, and a legal defense cost cap. After ISO proposed 1984 forms that omitted some of these changes, Hartford persuaded General Reinsurance Corporation, the largest American reinsurer, to procure the modifications or derail the program. The Reinsurance Association of America agreed to boycott the 1984 forms unless the changes were added, and domestic and London reinsurers informed ISO they would withhold reinsurance until the forms were altered. ISO then withdrew the 1984 forms and adopted 1986 forms containing a retroactive date and pollution exclusion; it later withdrew support services for the 1973 form. Separate agreements among London reinsurers required primary insurers to switch to claims-made policies and excluded pollution coverage from reinsurance contracts covering North American risks. Nineteen states and many private plaintiffs filed 36 complaints alleging that these actions violated section 1 of the Sherman Act. The cases were consolidated in the Northern District of California. The District Court granted motions to dismiss in 1989, holding the conduct fell within McCarran-Ferguson immunity and applying international comity to the foreign defendants. The Ninth Circuit reversed in 1991. The Supreme Court granted certiorari in 1992.
View caseJoanna Jung sues a federal agency in district court seeking review of an immigration benefits denial. The agency moves to dismiss, arguing the governing statute channels all such claims exclusively to an administrative tribunal. The court examines whether it possesses subject-matter jurisdiction over that category of claims.
In 1993 Congress amended the Gun Control Act of 1968 by enacting the Brady Handgun Violence Prevention Act, which directed the Attorney General to create a national instant background-check system by November 30, 1998, and imposed interim requirements on firearms dealers and chief law enforcement officers until that system became operational. Under the interim scheme a dealer proposing to transfer a handgun had to obtain a sworn Brady Form from the purchaser, verify the purchaser's identity, forward notice and a copy of the form to the CLEO of the purchaser's residence, and wait five business days before completing the sale unless the CLEO notified the dealer that the transfer would not violate the law. Jay Printz, CLEO for Ravalli County, Montana, and Richard Mack, CLEO for Graham County, Arizona, filed separate federal actions challenging the constitutionality of the interim provisions that required CLEOs to perform background checks and related tasks. In each case the district court held that the obligation imposed on CLEOs was unconstitutional but severable from the remainder of the Act, leaving in place a voluntary background-check system. The Ninth Circuit consolidated the appeals and reversed, holding that none of the Brady Act's interim provisions violated the Constitution. The Supreme Court granted certiorari.
View caseJavier Jimenez, a detainee at Guantanamo, petitions for habeas relief after a military commission conviction. He argues the commission lacks authority because Congress never authorized the procedures used. The Court examines whether the commission possessed statutory jurisdiction over the charged offenses.
Salim Ahmed Hamdan, a Yemeni national, was captured by militia forces in Afghanistan in November 2001 during hostilities between the United States and the Taliban regime that then governed the country. The militia turned him over to the United States military, which transported him to the detention facility at Guantanamo Bay, Cuba, in June 2002. Over a year later, on July 3, 2003, the President determined that Hamdan was eligible for trial by military commission for then-unspecified crimes. Subsequently, on July 13, 2004, the government charged Hamdan with one count of conspiracy to commit offenses triable by military commission. The charging document alleged that from February 1996 to November 2001 he had joined an enterprise with al Qaeda members and committed four overt acts in furtherance of that conspiracy. Hamdan then filed petitions for writs of habeas corpus and mandamus in the United States District Court for the District of Columbia to challenge both the authority of the military commission and the procedures it would employ. The District Court granted Hamdan's habeas petition on November 8, 2004, stayed the commission proceedings, and concluded that the commission lacked authority under the law of war and violated both the Uniform Code of Military Justice and Common Article 3 of the Geneva Conventions. The Court of Appeals for the District of Columbia Circuit reversed that decision, holding that the Geneva Conventions were not judicially enforceable and that the commission's jurisdiction and procedures were lawful. The Supreme Court granted certiorari on November 7, 2005. On December 30, 2005, Congress enacted the Detainee Treatment Act, after which the government moved to dismiss the case for lack of jurisdiction. The Supreme Court postponed ruling on the motion and later denied it, retaining jurisdiction over the appeal.
View caseNo. Subject-matter jurisdiction is conferred only by constitution or statute and cannot be created by the parties' consent or conduct. A court must dismiss whenever it determines the power is absent, even if the parties have litigated for years.
Supporting sources
Jurisdiction ratione materiae concerns the court's power over the type of claim or controversy. Personal jurisdiction concerns the court's power over the particular defendant. Both must exist for a valid judgment, but only subject-matter jurisdiction defects require dismissal at any stage.
Supporting sources
A federal court may examine subject-matter jurisdiction at any time, including after trial or on appeal. The obligation to confirm the existence of this power is independent of any party's motion.
Supporting sources