Subject Matter Jurisdiction

Rule

Federal courts are courts of limited jurisdiction. They may only hear cases authorized by Article III of the Constitution and a statutory grant from Congress. Unlike personal jurisdiction, subject matter jurisdiction cannot be waived and may be raised at any time — even by the court sua sponte. Parties cannot consent to SMJ.

Elements / Test

Federal Question Jurisdiction (28 U.S.C. § 1331)

1. Plaintiff’s claim arises under the Constitution, laws, or treaties of the United States
2. Federal issue appears on the face of the well-pleaded complaint (not in anticipated defenses or counterclaims) — Louisville & Nashville R.R. v. Mottley
3. Embedded state-law claims with federal issues: federal issue must be (a) necessarily raised, (b) actually disputed, (c) substantial, and (d) capable of resolution without disrupting federal-state balance — Grable & Sons v. Darue

Diversity Jurisdiction (28 U.S.C. § 1332)

1. Complete diversity: every plaintiff must be diverse from every defendant (Strawbridge rule)
2. Amount in controversy exceeds $75,000 (exclusive of interest and costs)
3. Citizenship:
   • Natural persons: domicile (physical presence + intent to remain indefinitely)
   • Corporations: state of incorporation AND principal place of business (nerve center — Hertz Corp. v. Friend)
   • Unincorporated entities (LLCs, partnerships): citizenship of ALL members
   • Legal representative of estate/infant: citizenship of the represented party (§ 1332(c)(2))
4. Citizenship determined at time of filing; subsequent changes do not destroy jurisdiction

Supplemental Jurisdiction (28 U.S.C. § 1367)

1. Court has original jurisdiction over at least one claim
2. Additional claim forms part of the same case or controversy (common nucleus of operative fact — United Mine Workers v. Gibbs)
3. § 1367(b) limitation in diversity cases: no supplemental jurisdiction over claims by plaintiffs against parties joined under Rules 14, 19, 20, or 24, if it would destroy complete diversity

Exceptions

• Domestic relations exception: federal courts decline jurisdiction over divorce, alimony, child custody decrees
• Probate exception: federal courts decline jurisdiction over administration of estates
• Abstention doctrines: Pullman, Younger, Burford — court declines to exercise jurisdiction as matter of comity
• Declination of supplemental jurisdiction (§ 1367(c)): novel state law question; state law claims predominate; anchor claim dismissed; exceptional circumstances

Policy

• Diversity jurisdiction prevents local bias against out-of-state litigants
• Federal question jurisdiction ensures uniform application of federal law
• Supplemental jurisdiction promotes judicial efficiency by resolving related claims together

Key Cases

• Louisville & Nashville R.R. v. Mottley — well-pleaded complaint rule; anticipating federal defense insufficient
• Hertz Corp. v. Friend — principal place of business = nerve center (executive headquarters)
• United Mine Workers v. Gibbs — common nucleus of operative fact test for supplemental jurisdiction

Covered In

• Civil Procedure I
• Civil Procedure II