Also known as: justiciability concern · justiciable · justiciability · justiciable controversy · case or controversy
Written by attorneys — see sources below.
Constitutional limits on federal judicial power that confine courts to resolving concrete disputes between adverse parties. These limits derive from the Article III case-or-controversy requirement. A claim fails these limits when it presents only a hypothetical controversy, a generalized grievance, or an issue textually committed to another branch without judicially manageable standards.
Jorge Juarez, a voter in a malapportioned district, sued state officials alleging that the legislative map violated equal protection by diluting his vote. The district court applied the six-factor test and found no textually committed issue, no absence of manageable standards, and no other political-question bar. The case therefore advanced to the merits on the vote-dilution claim.
Jennifer Jackson sued in federal court on a copyright claim against Jiang Textiles and added a related state unfair-competition count arising from the same unauthorized copying. The court confirmed both claims formed part of the same Article III case or controversy. Supplemental jurisdiction therefore extended only because justiciability was satisfied.
Judy Jacobs asserted a federal copyright claim and a state unfair-competition claim against Jenkins Apparel based on identical facts involving misappropriation of a design. The court found the claims shared a common nucleus forming one constitutional case or controversy. It therefore exercised pendent jurisdiction after confirming justiciability.
Jason Jung sought declaratory relief against a city ordinance that had never been enforced against his business. The court found no realistic threat of enforcement and therefore no live case or controversy. The claim was dismissed as nonjusticiable.
Jose Jimenez, a federal taxpayer, challenged a congressional appropriation alleged to violate the Establishment Clause. The court applied the Flast nexus test and concluded that the claim satisfied Article III standing requirements. The suit therefore proceeded on the merits.
Congress enacted the Elementary and Secondary Education Act of 1965. That statute authorized federal grants under Titles I and II to state and local educational agencies. Seven individuals who paid federal income taxes filed a complaint in the United States District Court for the Southern District of New York. They sued the Secretary of Health, Education, and Welfare and the Commissioner of Education in their official capacities. The complaint alleged that federal funds appropriated under the Act were being disbursed with the consent and approval of the defendants. Those funds were being used to finance instruction in reading, arithmetic, and other subjects in religious schools and to purchase textbooks and instructional materials for use in such schools. The complaint attacked the specific criterion of 20 U.S.C. § 241e(a)(2) that to the extent consistent with the number of educationally deprived children in the school district of the local educational agency who are enrolled in private elementary and secondary schools, such agency has made provision for including special educational services and arrangements in which such children can participate. The plaintiffs alleged that these expenditures constituted compulsory taxation for religious purposes in violation of the Establishment and Free Exercise Clauses of the First Amendment. They requested a declaratory judgment that the expenditures were unauthorized or alternatively that the Act was unconstitutional to that extent together with an injunction restraining approval of further expenditures for the challenged purposes. The defendants moved to dismiss the complaint on the ground that the plaintiffs lacked standing. A three-judge district court granted the motion and dismissed the complaint. The plaintiffs appealed directly to the Supreme Court pursuant to 28 U.S.C. § 1253 and the Court noted probable jurisdiction.
View caseJacob Jennings sued a diverse defendant for damages exceeding the jurisdictional minimum and joined additional plaintiffs whose individual claims fell short. The court held the claims formed part of the same Article III case or controversy. All claims therefore remained in federal court after justiciability review.
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 caseA claim is justiciable when none of the six Baker factors is present, including the absence of a textually demonstrable commitment to another branch and the presence of judicially manageable standards such as population equality. When those standards exist, courts may adjudicate vote-dilution claims.
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A challenge is nonjusticiable when the statute has never been enforced, no realistic threat of enforcement exists, and the dispute is therefore hypothetical. Federal courts will not issue advisory opinions on dormant laws.
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Supplemental jurisdiction exists only over claims that form part of the same Article III case or controversy as the anchor claim. Claims lacking that shared nucleus fall outside the constitutional limit.
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Article III standing requires a particularized and concrete injury in fact. A purely procedural violation that creates no real risk of harm does not satisfy that requirement and renders the claim nonjusticiable.
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…therefore, agree with the District Court that Jane Roe had standing to undertake this litigation, that she presented a justiciable controversy, and that the termination of her 1970 pregnancy has not rendered her case moot. B. Dr. Hallford. The doctor's position is different. He entered Roe's litigation as a…