Background
Jenifer Arbaugh was employed as a bartender and waitress at the Moonlight Cafe, a New Orleans restaurant, from May 2000 until February 2001. During this time, she alleged that she was continually sexually harassed by one of the restaurant's owners.
On November 8, 2001, Arbaugh filed suit in the United States District Court for the Eastern District of Louisiana, asserting claims against Y & H Corporation (the operator of the Moonlight Cafe) and the owner she alleged harassed her. Her complaint alleged sexual harassment in violation of Title VII, in addition to various tort claims under Louisiana state law. Arbaugh's complaint asserted that her Title VII claim invoked the court's federal question jurisdiction to hear her case. [2]
District Court proceedings
After a two-day jury trial in October 2002, a $40,000 verdict was returned in favor of Arbaugh. Two weeks later, Y&H filed a motion to dismiss for lack of subject matter jurisdiction, asserting for the first time in the litigation that it did not qualify as an "employer" under Title VII because it did not employ fifteen or more employees for 20 or more calendar weeks during the relevant time period. [3] If Arbaugh did not state a valid claim under Title VII, Y&H argued that she accordingly failed to invoke federal question jurisdiction.
Though the district court considered it "unfair and a waste of judicial resources" for the defendant to raise the issue after trial had already been conducted, the court nevertheless ordered both parties to conduct post-trial discovery on the issue, because objections to subject matter jurisdiction could be raised at any stage of litigation. [4] After converting the motion to dismiss to a motion for summary judgment, the district court determined that the employer criteria were not satisfied, because Y&H's delivery drivers, owner-managers, and their shareholder wives were not "employees" for Title VII purposes, and the company could not meet the requirement without their inclusion. The court vacated its prior judgment in favor of Arbaugh, dismissed her Title VII claim with prejudice, and her state-law claims without prejudice.
Court of Appeals decision
Arbaugh appealed the reversal to the United States Court of Appeals for the Fifth Circuit, which affirmed the district court's decision. [5] Bound by its prior decisions, the Court of Appeals held that a defendant's failure to qualify as an "employer" under Title VII deprives a district court of subject matter jurisdiction. [6] The court ruled that dismissal for want of subject matter jurisdiction was proper because the record warranted the conclusion that Y&H did not employ the requisite 15 employees. [7]
Opinion of the Court
Arbaugh petitioned for certiorari to the U.S. Supreme Court, which granted review of the decision to resolve conflicting opinions among the Courts of Appeals on the question whether Title VII's employee-numerosity requirement was jurisdictional or simply an element of a plaintiff's claim for relief. The U.S. Solicitor General was granted permission to participate in oral argument as amicus curiae , to argue in support of Arbaugh's legal interpretation. [8]
The Supreme Court unanimously [9] reversed the Fifth Circuit's decision in an opinion delivered by Justice Ruth Bader Ginsburg, holding that the threshold number of employees for application of Title VII is an element of a plaintiff's claim for relief, not a jurisdictional issue.
Ginsburg's majority opinion
The Court first noted that federal question case law often erroneously conflated subject matter jurisdiction requirements with the required elements of a claim for relief. Courts often did not specify whether a case was dismissed for lack of subject matter jurisdiction or for failure to state a claim. The Supreme Court had itself in prior Title VII decisions declined to comment on whether the lower court had properly designated the plaintiff's failure to state a claim under Title VII as a failure to establish subject matter jurisdiction, preferring instead to focus on the lower court's construction of the statute.
The court described the three main consequences that followed from subject matter jurisdiction limitations, and found that these did not apply to the employee-numerosity requirement. First, because subject matter jurisdiction involves a court's power to hear a case, it can never be forfeited or waived. All courts have an independent obligation to determine whether subject-matter jurisdiction exists, even in the absence of a challenge from any party. The Court believed that nothing in the text of Title VII indicated that Congress intended courts, on their own motion, to assure that the employee-numerosity requirement was met.
Second, if subject-matter jurisdiction turns on contested facts, the trial judge may be authorized to review the evidence and resolve the dispute on her own. By contrast, if satisfaction of an essential element of a claim for relief is at issue, the jury is the proper trier of fact.
Third, when a federal court concludes that it lacks subject-matter jurisdiction, the court must dismiss the complaint in its entirety, which is why the trial court dismissed Arbaugh's state-law claims even though they had already been tried and determined by a jury. In contrast, when a court grants a motion to dismiss for failure to state a federal claim, the court generally retains discretion to exercise supplemental jurisdiction to hear the state-law claims. [10]
The Court noted that Congress could make the employee-numerosity requirement "jurisdictional" if it wanted to, similar to how it made the "amount-in-controversy" threshold an ingredient of subject matter jurisdiction in delineating diversity jurisdiction. [11] However, the 15-employee threshold appears in a separate provision from Title VII's jurisdictional provision, [12] and does not speak in jurisdictional terms or refer in any way to the jurisdiction of the district courts. Given the "unfairness" and "waste of judicial resources," entailed in tying the employee-numerosity requirement to subject-matter jurisdiction, the Court considered it "the sounder course" to refrain from construing the requirement as jurisdictional. The Court concluded by stating that "when Congress does not rank a statutory limitation on coverage as jurisdictional, courts should treat the restriction as nonjurisdictional in character."
Federal jurisdiction refers to the legal scope of the government's powers in the United States of America.
In United States law, a motion is a procedural device to bring a limited, contested issue before a court for decision. It is a request to the judge to make a decision about the case. Motions may be made at any point in administrative, criminal or civil proceedings, although that right is regulated by court rules which vary from place to place. The party requesting the motion may be called the moving party, or may simply be the movant. The party opposing the motion is the nonmoving party or nonmovant.
The Equal Pay Act of 1963 is a United States labor law amending the Fair Labor Standards Act, aimed at abolishing wage disparity based on sex. It was signed into law on June 10, 1963, by John F. Kennedy as part of his New Frontier Program. In passing the bill, Congress stated that sex discrimination:
Subject-matter jurisdiction, also called jurisdiction ratione materiae, is a legal doctrine holding that a court can only hear and decide cases of a particular type. The subject matter jurisdiction of a court may be described as either limited jurisdiction, meaning it is able to hear only certain types of cases, or general jurisdiction, meaning it is presumed able to hear and decide all types of cases. For instance, a bankruptcy court only has the authority to hear bankruptcy cases.
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. They are the companion to the Federal Rules of Criminal Procedure. Rules promulgated by the United States Supreme Court pursuant to the Rules Enabling Act become part of the FRCP unless, within seven months, the United States Congress acts to veto them. The Court's modifications to the rules are usually based upon recommendations from the Judicial Conference of the United States, the federal judiciary's internal policy-making body.
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction that gives United States federal courts the power to hear lawsuits that do not involve a federal question. For a 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, federal courts will normally lack the jurisdiction to hear it unless it involves a federal question, and the lawsuit would need to be heard in state court instead.
In the United States, removal jurisdiction allows a defendant to move a civil action or criminal case 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.
Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005), is a United States Supreme Court case in which the Court clarified the Rooker-Feldman doctrine and its relation to preclusion and concurrent jurisdiction.
Supplemental jurisdiction, also sometimes known as ancillary jurisdiction or pendent 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.
The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.
Caterpillar Inc. v. Lewis, 519 U.S. 61 (1996), held that federal jurisdiction predicated on diversity of citizenship can be sustained even if there did not exist complete diversity at the time of removal to federal court, so long as complete diversity exists at the time the district court enters judgment.
Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007), is an employment discrimination decision of the Supreme Court of the United States. Employers cannot be sued under Title VII of the Civil Rights Act of 1964 over race or gender pay discrimination if the claims are based on decisions made by the employer 180 days ago or more. Justice Alito held for the five-justice majority that each paycheck received did not constitute a discrete discriminatory act, even if it was affected by a prior decision outside the time limit. Ledbetter's claim of the “paycheck accrual rule” was rejected. The decision did not prevent plaintiffs from suing under other laws, like the Equal Pay Act, which has a three-year deadline for most sex discrimination claims, or 42 U.S.C. 1981, which has a four-year deadline for suing over race discrimination.
Watson v. Fort Worth Bank & Trust, 487 U.S. 977 (1988), is a United States Supreme Court case on United States labor law, concerning proof of disparate treatment under the Civil Rights Act of 1964.
The Narragansett land claim was one of the first litigations of aboriginal title in the United States in the wake of the U.S. Supreme Court's landmark Oneida Indian Nation of New York v. County of Oneida (1974), or Oneida I, decision. The Narragansett claimed a few thousand acres of land in and around Charlestown, Rhode Island, challenging a variety of early 19th century land transfers as violations of the Nonintercourse Act, suing both the state and private land owners.
Reed Elsevier, Inc. v. Muchnick, 559 U.S. 154 (2010), was a decision by the Supreme Court of the United States involving copyright law. The Court held that failure to register a copyright under Section 411 (a) of the United States Copyright Act does not limit a Federal Court's jurisdiction over claims of infringement regarding unregistered works.
County of Washington v. Gunther, 452 U.S. 161 (1981), is a United States labor law case concerning discrimination and the lower standards of protection for gender pay because of the Bennett Amendment in Title VII of the Civil Rights Act of 1964, §703(h).
Young v. United Parcel Service, 575 U.S. 206 (2015), is a United States Supreme Court case that the Court evaluated the requirements for bringing a disparate treatment claim under the Pregnancy Discrimination Act. In a 6–3 decision, the Court held that to bring such a claim, a pregnant employee must show that their employer refused to provide accommodations and that the employer later provided accommodations to other employees with similar restrictions. The Court then remanded the case to the United States Court of Appeals for the Fourth Circuit to determine whether the employer engaged in discrimination under this new test.
Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2015), was a case in which the Supreme Court of the United States clarified procedures for removing a class action lawsuit from state court to federal court. The case involved a dispute about revenue from oil and gas leases in which the defendant filed a motion to remove the case from a state court in Kansas to the United States District Court for the District of Kansas. However, the plaintiff argued that the defendant's motion was defective because the defendant's notice of removal did not include evidence demonstrating that the amount in controversy satisfied the jurisdictional threshold. The United States District Court for the District of Kansas ultimately ruled the case should be returned to the state court, and the United States Court of Appeals for the Tenth Circuit declined to review the district court's decision.
Corporation of Presiding Bishop v. Amos, 483 U.S. 327 (1987), is a United States Supreme Court case in which the court decided that the exemption of religious organizations from the prohibition of religious discrimination in employment in Title VII of the Civil Rights Act is constitutional. Appellee Arthur Frank Mayson worked for 16 years in an organization operated by the Church of Jesus Christ of Latter-day Saints. He was terminated from employment when he "failed to qualify for a temple recommend, that is, a certificate that he is a member of the Church and eligible to attend its temples." He filed suit in district court, arguing that his firing violated discrimination on the basis of religion in Title VII of the Civil Rights Act. The district court agreed. The case was appealed directly to the Supreme Court. The Supreme Court reversed, holding that Title VII's exemption of religious organizations from the prohibition on religious discrimination, even in secular activities, did not violate the First Amendment.
A grant of appellate review is dismissed as improvidently granted (DIG) when a court with discretionary appellate jurisdiction later decides that it should not review the case. Notably, the Supreme Court of the United States occasionally grants a petition of the writ of certiorari, only to later DIG the case.
