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In United States law, federal question jurisdiction is a type of subject-matter jurisdiction that gives United States federal courts the power to hear civil cases where the plaintiff alleges a violation of the United States Constitution, federal law, or a treaty to which the United States is a party. The federal question jurisdiction statute is codified at 28 U.S.C. § 1331.
The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.
Article III of the United States Constitution permits federal courts to hear such cases, so long as the United States Congress passes a statute to that effect. However, when Congress passed the Judiciary Act of 1789, which authorized the newly created federal courts to hear such cases, it initially chose not to allow the lower federal courts to possess federal question jurisdiction for fear that it would make the courts too powerful. The Federalists briefly created such jurisdiction in the Judiciary Act of 1801, but it was repealed the following year, and not restored until 1875.
Unlike diversity jurisdiction, which is based on the parties coming from different states, federal question jurisdiction no longer has any amount in controversy requirement—Congress eliminated this requirement in actions against the United States in 1976, and in all federal question cases in 1980. Therefore, a federal court can hear a federal question case even if no money is sought by the plaintiff.
To meet the requirement of a case "arising under" federal law, the federal question must appear on the face of the plaintiff's complaint. [1] There has been considerable dispute over what constitutes a "federal question" in these circumstances, but it is now settled law that the plaintiff cannot seek the jurisdiction of a federal court merely because it anticipates that the defendant is going to raise a defense based on the Constitution, or on a federal statute. [2] This "well-pleaded complaint" rule has been criticized by legal scholars, but Congress has so far chosen not to change the law, although the Supreme Court has made clear it is free to do so. [3] [4]
Eight years after Louisville & Nashville Railroad Company v. Mottley, Justice Oliver Wendell Holmes established the Holmes Test in American Well Works Co. v. Layne & Bowler Co. The opinion delivered for the court included the phrase: "A suit arises under the law that creates the cause of action." [5] For almost a hundred years this test was the foundation for federal question qualification under § 1331 until the Supreme Court modified it in Mims v. Arrow Financial Services (2012) to be whether “federal law creates [both] a private right of action and furnishes the substantive rules of decision.” [6]
Federal jurisdiction refers to the legal scope of the government's powers in the United States of America.
Subject-matter jurisdiction is the authority of a court to hear cases of a particular type or cases relating to a specific subject matter. For instance, bankruptcy court only has the authority to hear bankruptcy cases.
An abstention doctrine is any of several doctrines that a United States court may apply to refuse to hear a case if hearing the case would potentially intrude upon the powers of another court. Such doctrines are usually invoked where lawsuits involving the same issues are brought in two different court systems at the same time.
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction that gives U.S. federal courts the power to hear lawsuits that do not involve a federal question. For a U.S. federal court to have diversity jurisdiction over a lawsuit, two conditions must be met. First, there must be "diversity of citizenship" between the parties, meaning the plaintiffs must be citizens of different U.S. states than the defendants. Second, the lawsuit's "amount in controversy" must be more than $75,000. If a lawsuit does not meet these two conditions, U.S. federal courts will normally lack the power to hear it unless it involves a federal question, and the lawsuit would need to be heard in state court instead.
Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), was a landmark decision of the U.S. Supreme Court in which the Court held that that there is no general American federal common law and that U.S. federal courts must apply state law, not federal law, to lawsuits between parties from different states that do not involve federal questions. In reaching this holding, the Court overturned almost a century of federal civil procedure case law, and established the foundation of what remains the modern law of diversity jurisdiction as it applies to United States federal courts.
The Erie doctrine is a fundamental legal doctrine of civil procedure in the United States which mandates that a federal court called upon to resolve a dispute not directly implicating a federal question must apply state substantive law.
Giles v. Harris, 189 U.S. 475 (1903), was an early 20th-century United States Supreme Court case in which the Court upheld a state constitution's requirements for voter registration and qualifications. Although the plaintiff accused the state of discriminating in practice against black citizens, the Court found that the requirements applied to all citizens and refused to review the results "in practice," which it considered overseeing the state's process. As there was no stated intent in law to disenfranchise blacks, the Court upheld the state law.
Amount in controversy is a term used in civil procedure to denote the amount at stake in a lawsuit, in particular in connection with a requirement that persons seeking to bring a lawsuit in a particular court must be suing for a certain minimum amount before that court may hear the case.
Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), was a case in which the United States Supreme Court enunciated a rule of civil procedure that would eventually become known as the Rooker-Feldman doctrine (also named for the later case of District of Columbia Court of Appeals v. Feldman, 460 U.S. 462. The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.
Louisville & Nashville Railroad Company v. Mottley, 211 U.S. 149 (1908), was a United States Supreme Court decision that held that under the existing statutory scheme, federal question jurisdiction could not be predicated on a plaintiff's anticipation that the defendant would raise a federal statute as a defense. Instead, such jurisdiction can only arise from a complaint by the plaintiff that the defendant has directly violated some provision of the Constitution, laws, or treaties of the United States. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.
The Supreme Court of the United States has interpreted the Case or Controversy Clause of Article III of the United States Constitution as embodying two distinct limitations on exercise of judicial review: a bar on the issuance of advisory opinions, and a requirement that parties must have standing.
In the United States, removal jurisdiction allows a defendant to move a civil action filed in a state court to the United States district court in the federal judicial district in which the state court is located. A federal statute governs removal.
American Well Works Co. v. Layne & Bowler Co., 241 U.S. 257 (1916), was a United States Supreme Court case governing the scope of federal question jurisdiction.
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006), is a United States Supreme Court decision involving Title VII of the Civil Rights Act of 1964, which provides a private cause of action to victims of employment discrimination. The Court ruled that Title VII's "employee-numerosity requirement," which limits potential defendants to those maintaining at least fifteen employees, is not a limit on a court's jurisdiction to hear Title VII claims. The requirement is instead a substantive element of a Title VII claim, which means that a defendant must raise the issue prior to verdict or the requirement will be waived.
Supplemental jurisdiction is the authority of United States federal courts to hear additional claims substantially related to the original claim even though the court would lack the subject-matter jurisdiction to hear the additional claims independently. 28 U.S.C. § 1367 is a codification of the Supreme Court's rulings on ancillary jurisdiction and pendent jurisdiction and a superseding of the Court's treatment of pendent party jurisdiction.
Merrell Dow Pharmaceuticals Inc. v. Thompson, 478 U.S. 804 (1986), was a United States Supreme Court decision involving the original jurisdiction of the federal district courts under 28 U.S.C. § 1331.
Southern Pacific Company v. Jensen, 244 U.S. 205 (1917), was a United States Supreme Court case concerning the geographical extent of state workers' compensation laws. The Court held that the New York Workmen's Compensation Act, as applied to laborers in the New York Harbor, intruded on federal admiralty jurisdiction, and that civil suits arising within this jurisdiction were subject to the common law of the sea. The compensation statute passed by the state interfered with federal power and was therefore unconstitutional.
Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005), was a case in which the Supreme Court of the United States held that 28 U.S.C. § 1367 permits supplemental jurisdiction over joined claims that do not individually meet the amount-in-controversy requirements of § 1332, provided that at least one claim meets the amount-in-controversy requirements.
Smith v. Kansas City Title & Trust Co., 255 U.S. 180 (1921), was a United States Supreme Court case that helped define the range and scope of federal question jurisdiction in state corporate law matters. The case dealt with whether or not a district court had the power to uphold the constitutional validity of the Federal Farm Loan Act of 1916.
Home Depot U. S. A., Inc. v. Jackson, 587 U.S. ___ (2019), was a United States Supreme Court case which determined that a third-party defendant to a counterclaim submitted in a state-court civil action cannot remove their case to federal court. The Court explained, in a 5–4 decision, that although a third-party counterclaim defendant is a "defendant to a claim," removal can only be performed by the defendant to a "civil action." And this holds true even when the counterclaim is in the form of a class action. The Class Action Fairness Act of 2005 permits removal by "any defendant to a class action" but this does not extend removal rights to a third-party counterclaim defendant because they are not a defendant to the original case.