Also known as: ratione materiae · subject-matter jurisdiction · jurisdiction ratione materiae
Written by attorneys — see sources below.
A basis for a court's authority to adjudicate a dispute arising from the nature of the claim or controversy presented rather than from the parties' identities or the location of property.
Rebecca Ross filed a complaint in federal district court asserting only state-law tort claims against a local defendant and referencing national environmental guidelines without tying them to any federal statute. The defendant moved under Rule 12(h)(3) after affidavits showed incomplete diversity. The court determined it lacked subject-matter jurisdiction and dismissed the action.
Ruby Rivera sued a state agency in federal court on state-law claims while adding a federal statutory count. The agency filed a Rule 12(b)(1) motion supported by evidence that the federal claim was insubstantial. The court examined the face of the complaint and granted the motion for lack of subject-matter jurisdiction.
Raymond Ramos and other voters sued state officials in federal court alleging that legislative districts violated equal protection. The district court dismissed on the ground that the claim presented a nonjusticiable political question. The Supreme Court reversed, holding that the federal courts possessed subject-matter jurisdiction over the constitutional claim.
In 1901 the Tennessee General Assembly enacted a statute apportioning the Senate with thirty-three members and the House of Representatives with ninety-nine members among the state's ninety-five counties. The Tennessee Constitution required a decennial enumeration of qualified voters and reapportionment of both houses on that basis. The General Assembly performed reapportionments after the enumerations of 1871, 1881, and 1891. After 1901 every proposal for reapportionment failed to pass. Between 1901 and 1960 the state's population grew from 2,020,616 to 3,567,089. The number of persons eligible to vote rose from 487,380 to 2,092,891. Substantial redistribution occurred from rural to urban counties. Appellants were residents and qualified voters of the urban counties of Davidson, Hamilton, Knox, Montgomery, and Shelby. They brought a civil action in the United States District Court for the Middle District of Tennessee against the Secretary of State, Attorney General, Coordinator of Elections, and members of the State Board of Elections. The complaint was filed under 42 U.S.C. §§ 1983 and 1988. It alleged that continued application of the 1901 statute debased their votes and denied equal protection of the laws. The complaint sought a declaratory judgment that the statute was unconstitutional. It also sought an injunction against conducting further elections under the statute. Alternative relief included at-large elections or a court-ordered reapportionment. A three-judge district court convened under 28 U.S.C. § 2281 dismissed the complaint. The court held that it lacked jurisdiction of the subject matter and that the complaint failed to state a claim upon which relief could be granted. The court characterized the controversy as a nonjusticiable political question. The Supreme Court noted probable jurisdiction. The case was argued in April 1961, set for reargument, reargued in October 1961, and decided on March 26, 1962.
Ronald Reed and other insurers sued California officials and foreign reinsurers in federal court alleging a conspiracy to restrict coverage. The defendants moved to dismiss on comity grounds. The Supreme Court held that the district court had subject-matter jurisdiction over the Sherman Act claims despite the foreign conduct.
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.
Rosa Ruiz, a debtor, sued a pipeline company in bankruptcy court for breach of contract. The defendant moved to withdraw the reference. The Supreme Court held that the bankruptcy court lacked subject-matter jurisdiction to enter final judgment on the state-law claim because it did not arise under title 11.
In 1978 Congress enacted the Bankruptcy Reform Act after nearly ten years of study. The statute established a United States bankruptcy court in each judicial district as an adjunct to the district court. It granted those courts jurisdiction over all civil proceedings arising under title 11 or arising in or related to cases under title 11. Bankruptcy judges appointed under the Act served fourteen-year terms. They were subject to removal by the judicial council of the circuit for incompetence, misconduct, neglect of duty, or disability. They received salaries subject to congressional adjustment. In January 1980 Northern Pipeline Construction Co. filed a petition for reorganization under the Act in the United States Bankruptcy Court for the District of Minnesota. In March 1980 Northern filed a separate suit in the same court against Marathon Pipe Line Co. seeking damages for alleged breaches of contract and warranty as well as for misrepresentation, coercion, and duress. Marathon moved to dismiss the suit on the ground that the Act unconstitutionally conferred Article III judicial power on bankruptcy judges who lacked life tenure and salary protection. The United States intervened to defend the statute. The Bankruptcy Court denied the motion to dismiss. On appeal the District Court reversed and dismissed the suit. Northern and the United States filed notices of appeal, and the Supreme Court noted probable jurisdiction.
Rowan Russell and other asbestos claimants sought certification of a nationwide class and approval of a settlement in federal court. Objectors challenged the court's power to bind future claimants. The Supreme Court held that the district court lacked subject-matter jurisdiction to approve a settlement that exceeded the limits of Rule 23.
In the early 1990s, the Judicial Panel on Multidistrict Litigation transferred all pending federal asbestos cases to the Eastern District of Pennsylvania for pretrial proceedings before Judge Weiner. Attorneys from the Plaintiffs' Steering Committee and the Center for Claims Resolution, a consortium of twenty former asbestos manufacturers, began settlement negotiations that initially addressed pending inventory claims but soon expanded to cover future claims. After CCR settled thousands of inventory plaintiffs' claims for more than $200 million through separate agreements, the parties on January 15, 1993, filed a single-day package. This package consisted of a complaint, answer, proposed settlement stipulation exceeding one hundred pages, and joint motion for conditional class certification in a new action not part of the MDL transfer. The complaint defined the class as all persons in the United States or its territories who had been exposed occupationally or through a spouse or household member to asbestos products attributable to CCR defendants and who had not filed suit as of January 15, 1993. This class encompassed both individuals with manifest diseases such as mesothelioma, lung cancer, and asbestosis and exposure-only individuals with no current symptoms. The group potentially numbered in the hundreds of thousands or millions. The accompanying stipulation created a no-fault administrative compensation matrix with fixed, non-inflation-adjusted award ranges for four disease categories. It imposed numerical caps on extraordinary claims and excluded compensation for medical monitoring, fear of future injury, and loss-of-consortium claims. A three-month opt-out period applied. The District Court conditionally certified the class under Rule 23(b)(3) for settlement purposes only, appointed class counsel, approved an extensive notice plan that reached millions of individuals, conducted fairness hearings, and entered orders finding the settlement fair while enjoining class members from pursuing separate asbestos suits. Objectors appealed, the Third Circuit vacated the certification, and the Supreme Court granted certiorari.
A federal court must dismiss whenever it determines that subject-matter jurisdiction is absent, even if the case has advanced to trial. The requirement cannot be waived by the parties or created by consent. Rule 12(h)(3) imposes this duty on the court at any stage of the proceedings.
A party may assert lack of subject-matter jurisdiction by motion under Rule 12(b)(1) or in the responsive pleading. The defense is never waived and may be raised at any time. When the motion is granted, the court must dismiss the action.
…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…
…issued in conformity with the court's per curiam opinion. The opinion reveals that the court rested its dismissal upon lack of subject-matter jurisdiction and lack of a justiciable cause of action without attempting to distinguish between these grounds. After noting that the plaintiffs challenged the existing legislative apportionment in…
…against two other defendants, a municipality and a utility company. 490 U. S., at 546-547. No independent basis for federal subject-matter jurisdiction existed over the state-law claims. The plaintiff could not have brought her entire action in state court, because federal
…contention, post , at 599, n. 4, that by refusing to waive our settled rule for purposes of this case we have made "federal subject-matter jurisdiction . . . a one-way street running the Executive Branch's way." That is so, we are told, because the Executive can dispel
…Circuit affirmed. Held: 1. The Second Circuit erred in considering §10(b)’s extraterritorial reach to raise a question of subject-matter jurisdiction, thus allowing dismissal under Rule 12(b)(1). What conduct §10(b) reaches is a merits question, while
No. The complaint must show on its face that the claim arises under federal law or satisfies diversity requirements. Mere citation of national guidelines without a federal private right of action is insufficient to invoke federal-question jurisdiction.
Supplemental jurisdiction exists when the state claims share a common nucleus of operative fact with a federal claim that is properly before the court. The claims must form part of the same case or controversy under Article III.
Yes. Jurisdiction turns on whether the well-pleaded complaint asserts a nonfrivolous right to relief under the Constitution or federal law. The existence of an implied cause of action is a merits question, not a jurisdictional prerequisite.