Hodgson v. Bowerbank
Citation and Court
9 U.S. (5 Cranch) 303 (1809), Supreme Court of the United States
Facts
Two alien parties — both British subjects — were on opposing sides of a lawsuit and sought to invoke the diversity jurisdiction of U.S. federal courts under a statute that purported to extend jurisdiction to suits between aliens.
Issue
Whether Congress may confer federal jurisdiction over a suit between two aliens, where Article III extends federal judicial power to suits “between a State, or the Citizens thereof, and foreign Citizens or Subjects.”
Holding
Federal courts lack jurisdiction over a suit entirely between alien parties because Article III does not extend the judicial power to such cases; Congress cannot grant jurisdiction beyond the Article III ceiling.
Rule / Doctrine
Article III sets an outer limit on federal subject-matter jurisdiction. Congress may not confer jurisdiction beyond what Article III permits. Diversity jurisdiction between aliens — without any U.S. party — exceeds Article III’s grant.
Significance
Hodgson v. Bowerbank is a foundational case for the proposition that Congress’s statutory grants of jurisdiction cannot exceed the Article III maximum. It remains relevant to discussions of alienage jurisdiction and constitutional limits on federal court power in transnational cases.