Subject matter jurisdiction is the court's power over the type of case. Federal courts have limited jurisdiction, so a federal plaintiff must point to a statute that authorizes the suit. The two main doors are diversity of citizenship and federal question. Unlike personal jurisdiction, this cannot be waived or consented to, and a court must dismiss on its own motion at any stage if it discovers the jurisdiction was never there.
Rule
- Diversity. Complete diversity between all plaintiffs and all defendants, plus an amount in controversy over 75,000 dollars.
- Citizenship. An individual is a citizen of the state of domicile. A corporation is a citizen of its state of incorporation and of the state where its principal place of business, the nerve center, is located.
- Federal question. The claim must arise under federal law, and under the well-pleaded complaint rule the federal issue must appear in the plaintiff's own claim, not in an anticipated defense.
- Supplemental jurisdiction. Related state claims that form part of the same case or controversy may be heard, subject to statutory limits in diversity cases.
- Removal. A defendant may move a case to federal court if it could have been brought there, with an extra restriction where a defendant is a citizen of the forum state.
- Not waivable. The objection may be raised at any time, including on appeal.
Leading cases
- Strawbridge v. Curtiss: diversity must be complete, so no plaintiff may share a state of citizenship with any defendant.
- Louisville and Nashville Railroad Co. v. Mottley: the federal question must appear on the face of the plaintiff's well-pleaded complaint, not in a defense the plaintiff expects.
- Hertz Corp. v. Friend: a corporation's principal place of business is its nerve center, normally the headquarters where the officers direct and control the business.
Where students go wrong
The first mistake is mixing this up with personal jurisdiction. One is power over the case, the other is power over the defendant, and only the second can be waived.
The second is misapplying the well-pleaded complaint rule. A plaintiff cannot create federal jurisdiction by predicting a federal defense, and a defendant cannot create it by raising one.
The third is being sloppy about citizenship. Domicile is residence plus intent to remain, and it does not change simply because someone is living elsewhere for a while.
FAQ
Can the parties agree to federal jurisdiction?
No. Consent cannot create subject matter jurisdiction, and a judgment entered without it is vulnerable long after the case is over.
How is the amount in controversy measured?
By the plaintiff's good faith allegation, and dismissal follows only where it appears to a legal certainty that the claim is worth less. A single plaintiff may aggregate claims against a single defendant.
What happens to state law claims in a federal case?
Supplemental jurisdiction lets the court hear claims that share a common nucleus of operative fact, though it may decline once the federal claims drop out.
Related terms
Working through this in your own casebook takes longer than reading it here. Syllume starts from your syllabus and turns each assigned case into a brief you can study from.