Also known as: limited jurisdictions · special jurisdiction · inferior jurisdiction
Written by attorneys — see sources below.
A court's power to adjudicate only those cases falling within categories expressly authorized by constitution or statute. Federal courts exemplify the category because their authority derives solely from Article III and implementing legislation rather than from any general reservoir of judicial power.
Lakeshore Industries holds a mortgage on property in a state that permits strict foreclosure. After default the mortgagee petitions the court to vest title directly without a sale. The court grants the request because the state's foreclosure statute authorizes strict foreclosure only in that limited jurisdiction.
Clear Plastics sues Atlantic Production in federal court on diversity grounds. After settlement the remaining claims involve only non-diverse parties and fall below the amount-in-controversy threshold. The district court dismisses because federal courts possess limited jurisdiction that cannot be retained once the original anchor claim disappears.
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 caseDred Scott files suit in federal circuit court asserting diversity. The defendant objects that the court lacks authority over the subject matter. The Supreme Court examines the limited jurisdiction of federal courts and holds that the plea must be considered even after later pleadings.
Dred Scott, along with his wife Harriet and their two children Eliza and Lizzie, was held as a slave by the defendant John F. A. Sandford in the State of Missouri. Scott initiated an action in the Circuit Court of the United States for the District of Missouri asserting his and his family's right to freedom. The declaration averred that Scott was a citizen of Missouri and the defendant a citizen of New York to establish diversity jurisdiction. The defendant responded with a plea in abatement asserting that the court lacked jurisdiction because Scott was not a citizen of Missouri. Scott was a negro of African descent whose ancestors were of pure African blood and had been brought into the country and sold as slaves. Scott demurred to this plea. The Circuit Court overruled the plea and required the defendant to answer over. The defendant then filed pleas in bar. After a trial on the merits the jury returned a verdict in favor of the defendant, leading to judgment for him. Scott then prosecuted a writ of error to the Supreme Court. The underlying facts showed that Scott had been the slave of Dr. Emerson, a surgeon in the United States Army. In 1834 Emerson took Scott from Missouri to Rock Island in Illinois, where he held him as a slave until 1836. Emerson then removed Scott to Fort Snelling in the Territory of Upper Louisiana north of thirty-six degrees thirty minutes north latitude, holding him there until 1838. Harriet, originally the slave of Major Taliaferro, was also brought to Fort Snelling and sold to Emerson. Scott and Harriet were married at Fort Snelling in 1836 with Emerson's consent, and their children were born there or during the return journey. In 1838 Emerson brought the family back to Missouri, where they resided until Emerson sold them to Sandford. The case reached the Supreme Court after two arguments. The Court ordered reargument on some of the points due to differences of opinion among the justices and the importance of the questions involved.
View caseA civilian dependent is tried by court-martial overseas for a capital offense. She petitions for habeas corpus in federal district court. The Supreme Court holds that the limited jurisdiction of federal courts does not extend to reviewing the military proceeding under the circumstances presented.
Mrs. Clarice Covert, a civilian, killed her husband, a sergeant in the United States Air Force, at an airbase in England where she was residing with him. Mrs. Dorothy Smith, also a civilian, killed her husband, a colonel in the United States Army, at a post in Japan where she was living with him. Both women were tried by courts-martial convened under Article 118 of the Uniform Code of Military Justice for the offense of murder and were sentenced to life imprisonment. The court-martial that tried Mrs. Covert was composed of Air Force officers after charges were preferred by Air Force personnel. The judgment was affirmed by the Air Force Board of Review but reversed by the Court of Military Appeals on grounds related to the defense of insanity, leaving a retrial pending in the District of Columbia. Mrs. Smith was tried by an Army court-martial. Her conviction was approved by the Army Board of Review and the Court of Military Appeals, after which she was confined in a federal penitentiary in West Virginia. While Mrs. Covert was held pending retrial, her counsel petitioned the United States District Court for the District of Columbia for a writ of habeas corpus. That court ordered her release. The Government appealed directly to the Supreme Court under 28 U.S.C. § 1252. Mrs. Smith's father petitioned the United States District Court for the Southern District of West Virginia for habeas corpus relief on her behalf. That court denied the writ, and while an appeal was pending in the Fourth Circuit the Supreme Court granted certiorari. The two cases were consolidated for argument. An executive agreement between the United States and Great Britain permitted United States military courts to exercise exclusive jurisdiction over offenses committed in Great Britain by American servicemen or their dependents. A similar administrative agreement governed jurisdiction in Japan. Both women were tried pursuant to Article 2(11) of the Uniform Code of Military Justice, which extends court-martial jurisdiction to persons accompanying the armed forces outside the continental United States subject to treaty or international law provisions.
View caseA former spouse seeks damages in federal court for alleged tortious interference with custody rights. The defendant moves to dismiss. The district court grants the motion because federal courts of limited jurisdiction do not entertain actions falling within the domestic-relations exception to diversity jurisdiction.
In September 1989 Carol Ankenbrandt, a citizen of Missouri, filed suit in the United States District Court for the Eastern District of Louisiana on behalf of her daughters L. R. and S. R. against Jon A. Richards and Debra Kesler, both citizens of Louisiana. The complaint alleged that Richards, the divorced father of the children, and Kesler, his female companion, had committed acts of sexual and physical abuse against the daughters and sought monetary damages. Federal jurisdiction rested solely on the diversity-of-citizenship provision of 28 U.S.C. § 1332. One month earlier, on August 9, 1989, a juvenile court in Jefferson Parish, Louisiana, had entered a judgment under state child-protection statutes that permanently terminated Richards' parental rights on account of the alleged abuse and permanently enjoined him from any contact with the children. On December 10, 1990, the District Court granted the respondents' motion to dismiss. The court cited In re Burrus for the proposition that the whole subject of domestic relations belongs to the laws of the States and invoked the domestic relations exception to diversity jurisdiction. It also relied on the abstention principles of Younger v. Harris to dismiss the complaint without prejudice. The Court of Appeals for the Fifth Circuit affirmed in an unpublished opinion. The Supreme Court granted certiorari limited to three questions concerning the existence and scope of any domestic relations exception and the propriety of Younger abstention in the case.
View caseA defendant appears in federal court and litigates for months before challenging personal jurisdiction. The plaintiff argues waiver occurred. The Supreme Court notes that federal courts of limited jurisdiction may examine whether the appearance truly conferred authority over the defendant.
Respondent Compagnie des Bauxites de Guinée is a Delaware corporation. Its principal place of business is in the Republic of Guinea, where it operates bauxite mines and processing facilities. Forty-nine percent of its stock is owned by the Republic of Guinea. The remaining fifty-one percent is owned by Halco (Mining) Inc., a Pennsylvania company that contracted to procure insurance for CBG. In 1973, Halco instructed broker Marsh & McLennan to obtain $20 million in business interruption coverage. The first $10 million was placed with Insurance Company of North America. The excess $10 million was placed through Bland Payne in the London market with 21 foreign insurers. Fourteen of those insurers are petitioners here. The placing slip was initialed effective February 12, 1974. The excess insurers adopted the INA policy terms. After CBG allegedly suffered mechanical problems causing more than $10 million in losses, it filed a two-count diversity action in the Western District of Pennsylvania in December 1975. CBG named INA on the first count and the excess insurers on the second count. The excess insurers answered by asserting lack of in personam jurisdiction. They later moved for summary judgment on that ground. CBG served its first document request in August 1976. The request sought copies of all business interruption policies issued between 1972 and 1975. After objections and motions to compel, the district court overruled the objections in June 1978. The court later narrowed the request to policies delivered in or covering risks in Pennsylvania. Petitioners stated the documents were held by London brokers. The court ordered them to request the files and gave successive extensions through November 1978. On December 21, 1978, after petitioners offered only to make four million files available in London, the district court warned that failure to produce the information within 60 days would result in an order under Rule 37(b)(2)(A) assuming jurisdiction. On April 19, 1979, the court found the material had not been produced and entered the sanction. It also made independent findings of jurisdiction under the Pennsylvania long-arm statute and by implicit consent through adoption of the INA contract. The Court of Appeals for the Third Circuit affirmed the jurisdictional holding as to all but three excess insurers. It relied solely on the validity of the Rule 37 sanction. The Supreme Court granted certiorari because the decision conflicted with Familia de Boom v. Arosa Mercantil, S.A., 629 F.2d 1134 (CA5 1980).
View caseFederal courts are courts of limited jurisdiction. They possess only the power authorized by the Constitution and statutes. Rule 12(h)(3) therefore requires dismissal whenever jurisdiction is found wanting, regardless of the stage of the proceedings.
The exception is a statutory construction of the diversity grant. It bars federal courts from entertaining actions for divorce, alimony, or child custody even when diversity and amount requirements appear satisfied. Other claims arising from the same facts may still proceed if they fall outside the exception.
No. The assignment creates an exclusive grant of subject-matter jurisdiction. An attempt by a court lacking that statutory authority renders any resulting decree void for want of jurisdiction.
The well-pleaded-complaint rule prevents removal. A federal issue that appears only because the plaintiff anticipates a defense does not confer federal-question jurisdiction on a court of limited jurisdiction.
…F. 3d 631 (CA10 1998). II A The district courts of the United States, as we have said many times, are "courts of limited jurisdiction. They possess only that power authorized by Constitution and statute," Kokkonen v. Guardian Life Ins. Co. of America , 511 U. S. 375, 377 (1994). In order to provide a federal forum for…