Strawbridge v. Curtiss
Citation: 7 U.S. (3 Cranch) 267 (U.S. Supreme Court, 1806)
Facts
Strawbridge and several other plaintiffs sued Curtiss and other defendants in federal court based on diversity of citizenship. Some of the plaintiffs and some of the defendants were citizens of Massachusetts, meaning there was not complete diversity between opposing parties.
Issue
Whether diversity jurisdiction under Article III requires that every plaintiff be diverse from every defendant — i.e., complete diversity — or whether partial diversity suffices.
Holding
Chief Justice Marshall held that the diversity statute requires complete diversity: every plaintiff must be a citizen of a different state from every defendant.
Rule
Complete diversity rule: for diversity jurisdiction under 28 U.S.C. § 1332, no plaintiff may share state citizenship with any defendant. If any plaintiff and any defendant are citizens of the same state, complete diversity is destroyed and the federal court lacks diversity jurisdiction.
Significance
Strawbridge established the complete diversity rule that governs diversity jurisdiction to this day. Though the case interprets the statutory grant of diversity jurisdiction (not the constitutional grant, which may permit minimal diversity), its rule has become foundational to diversity practice and is one of the first doctrines taught in Civil Procedure.