Also known as: case-or-controversy requirement · case or controversy requirement · cases and controversies requirement · case or controversy · Article III case or controversy
Written by attorneys — see sources below.
A constitutional limitation on federal judicial power that restricts courts to deciding actual disputes between adverse parties possessing concrete stakes in the outcome. The requirement bars advisory opinions on hypothetical questions and demands that claims share a common nucleus of operative fact when supplemental jurisdiction is asserted over related state-law theories.
Colin Chambers sued Crystal Dynamics in federal court alleging federal copyright infringement after the company copied his unpublished manuscript. He also asserted a state-law unfair-competition claim arising from the identical acts of copying and distribution. The court exercised supplemental jurisdiction over the state claim because both theories rested on the same set of facts.
Continental Bank sued Cascade Manufacturing in federal court on a diversity claim for breach of a supply contract. Cascade then impleaded Cedar Creek Farms for contribution on the same transaction. The court could hear the related state-law claims together because they formed part of the same case or controversy under Article III.
Craig Caldwell sought a declaratory judgment that a 1923 municipal ordinance banning certain artistic displays was unconstitutional. The city had never enforced the ordinance in a century and had assured the plaintiff in writing that it would not be applied. The court dismissed the action for lack of a justiciable case or controversy.
Christopher Collins and three other customers sued a retailer in federal court under diversity jurisdiction for overcharges on purchases. One plaintiff met the amount-in-controversy requirement while the others did not. The court exercised supplemental jurisdiction over the smaller claims because they arose from the same transactions.
In 1991, about 10,000 Exxon dealers filed a class-action suit against the Exxon Corporation in the United States District Court for the Northern District of Florida. They alleged an intentional and systematic scheme by which they were overcharged for fuel purchased from Exxon. The plaintiffs invoked the District Court's diversity jurisdiction under 28 U.S.C. § 1332(a). Each dealer's claim was for slightly less than the $75,000 jurisdictional minimum. After a unanimous jury verdict in favor of the plaintiffs, the District Court certified the case for interlocutory review on the question of supplemental jurisdiction over class members who did not meet the jurisdictional minimum. In a separate action, a 9-year-old girl sued Star-Kist in a diversity action in the United States District Court for the District of Puerto Rico. She sought damages for unusually severe injuries she received when she sliced her finger on a tuna can. Her family joined in the suit seeking damages for emotional distress and medical expenses. The District Court granted summary judgment to Star-Kist, finding that none of the plaintiffs met the minimum amount-in-controversy requirement. The Court of Appeals for the Eleventh Circuit upheld the District Court's extension of supplemental jurisdiction to the class members who did not meet the amount requirement. The Court of Appeals for the First Circuit ruled that the injured girl, but not her family members, had made allegations of damages in the requisite amount. It further held that section 1367 authorizes supplemental jurisdiction only when the district court has original jurisdiction over the action. In a diversity case, original jurisdiction is lacking if one plaintiff fails to satisfy the amount-in-controversy requirement. The Supreme Court granted certiorari to resolve the conflict among the Courts of Appeals. The cases were consolidated before the Supreme Court.
View caseCecilia Cabrera, a pregnant woman, challenged a state abortion statute in federal court. Two other plaintiffs alleged only possible future injury from contraceptive failure. The court held that only Cabrera presented a live case or controversy sufficient for standing.
In March 1970, Jane Roe, a single woman residing in Dallas County, Texas, instituted a federal action against the District Attorney of the county. She sought a declaratory judgment that the Texas criminal abortion statutes were unconstitutional on their face. She also sought an injunction restraining enforcement of the statutes. Roe alleged that she was unmarried and pregnant. She wished to terminate her pregnancy by an abortion performed by a competent licensed physician under safe clinical conditions. She was unable to obtain a legal abortion in Texas because her life did not appear to be threatened by continuation of the pregnancy. She could not afford to travel to another jurisdiction to secure a legal abortion. James Hubert Hallford, a licensed physician, sought and was granted leave to intervene in Roe's action. In his complaint he alleged that he had been arrested previously for violations of the Texas abortion statutes. Two such prosecutions were pending against him in the Criminal District Court of Dallas County. He described conditions of patients who came to him seeking abortions. He claimed that for many cases he was unable to determine whether they fell within or outside the exception recognized by Article 1196 of the Texas Penal Code. John and Mary Doe, a married couple, filed a companion complaint also naming the District Attorney as defendant. The Does alleged that they were a childless couple. Mrs. Doe was suffering from a neural-chemical disorder. Her physician had advised her to avoid pregnancy until her condition materially improved. She had discontinued use of birth control pills pursuant to medical advice. If she should become pregnant she would want to terminate the pregnancy by an abortion performed by a competent licensed physician under safe clinical conditions. The two actions were consolidated and heard together by a duly convened three-judge district court for the Northern District of Texas. Upon the filing of affidavits, motions were made for dismissal and for summary judgment. The court held that Roe and members of her class and Dr. Hallford had standing to sue and presented justiciable controversies. The Does had failed to allege facts sufficient to state a present controversy and did not have standing. It concluded that the Texas criminal abortion statutes were void on their face. The court dismissed the Does' complaint while denying injunctive relief. The plaintiffs Roe and Doe and the intervenor Hallford appealed to the Supreme Court from that part of the District Court's judgment denying the injunction. The defendant District Attorney cross-appealed from the grant of declaratory relief. Both sides also took protective appeals to the United States Court of Appeals for the Fifth Circuit. That court ordered the appeals held in abeyance pending decision by the Supreme Court.
View caseCharles Cunningham and other asbestos claimants sought approval of a global class settlement in federal court. The proposed class included future claimants who had not yet manifested injury. The court refused approval because the absent class members did not present a ripe case or controversy.
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.
View caseA federal court may exercise supplemental jurisdiction when the state claim forms part of the same case or controversy as a claim within the court's original jurisdiction. This occurs when the claims share a common nucleus of operative fact so that a plaintiff would ordinarily expect to try them together.
A challenge to an unenforced statute is nonjusticiable when there is no realistic threat of enforcement and the dispute remains hypothetical. Federal courts will not issue advisory opinions on dormant laws that pose no actual risk to the parties.
Yes. Even when original jurisdiction rests on diversity, the state claims must still form part of the same Article III case or controversy. Section 1367(b) may additionally bar supplemental jurisdiction over certain claims by plaintiffs against nondiverse parties joined under Rules 14, 19, 20, or 24.