Podcast
Questions and Answers
What is required for claims to be aggregated when multiple parties are involved?
What is required for claims to be aggregated when multiple parties are involved?
Claims can only be aggregated if they involve a single title or right which the parties have a common and undivided interest.
What is the significance of Article III, Section 2 in determining federal subject matter jurisdiction?
What is the significance of Article III, Section 2 in determining federal subject matter jurisdiction?
Article III, Section 2 establishes the federal courts' jurisdiction over cases arising under federal law and diversity of citizenship, ensuring that federal questions or citizens from different states can be adjudicated at the federal level.
Explain the complete diversity requirement under 1332.
Explain the complete diversity requirement under 1332.
Complete diversity requires that no plaintiff is from the same state as any defendant, including considerations of foreign nationals.
Explain the concept of the 'Potential Federal Ingredient Test' in relation to subject matter jurisdiction.
Explain the concept of the 'Potential Federal Ingredient Test' in relation to subject matter jurisdiction.
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What are the criteria for determining the citizenship of a natural person in diversity jurisdiction?
What are the criteria for determining the citizenship of a natural person in diversity jurisdiction?
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What are the four elements of the Essential Federal Ingredient Test (EFI) established in Gunn?
What are the four elements of the Essential Federal Ingredient Test (EFI) established in Gunn?
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What is the 'nerve center' test for corporate citizenship?
What is the 'nerve center' test for corporate citizenship?
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How is the citizenship of an unincorporated partnership determined for diversity purposes?
How is the citizenship of an unincorporated partnership determined for diversity purposes?
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Discuss the 'good faith test' regarding the amount in controversy for diversity jurisdiction.
Discuss the 'good faith test' regarding the amount in controversy for diversity jurisdiction.
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What are the implications of a direct attack on subject matter jurisdiction?
What are the implications of a direct attack on subject matter jurisdiction?
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What is the relevance of 'complete diversity' according to the Strawbridge case?
What is the relevance of 'complete diversity' according to the Strawbridge case?
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When must a lack of subject matter jurisdiction be challenged in federal court?
When must a lack of subject matter jurisdiction be challenged in federal court?
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How does the 'Legal Certainty Test' impact the determination of the amount in controversy?
How does the 'Legal Certainty Test' impact the determination of the amount in controversy?
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Under what conditions can multiple claims be aggregated to meet the amount in controversy requirement?
Under what conditions can multiple claims be aggregated to meet the amount in controversy requirement?
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What factors might indicate a change in domicile for a natural person?
What factors might indicate a change in domicile for a natural person?
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What is the role of 'minimal diversity' as discussed in the context of subject matter jurisdiction?
What is the role of 'minimal diversity' as discussed in the context of subject matter jurisdiction?
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Why are collateral attacks on federal district court judgments limited?
Why are collateral attacks on federal district court judgments limited?
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Under what conditions can an alien be treated in terms of citizenship for diversity?
Under what conditions can an alien be treated in terms of citizenship for diversity?
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Study Notes
Subject Matter Jurisdiction
- Federal courts have a duty to assess their own jurisdiction in every case (FRCP 12(h)(3)).
Federal Question Jurisdiction (§1331)
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Article III, Section 2: A case "arises under" federal law if the initial claim involves a federal ingredient, even if it's not central to the current dispute (Osborn).
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28 U.S.C. §1331: District courts have original jurisdiction over civil cases arising under the Constitution, laws, or treaties of the U.S.
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Creation Test (American Well Works): A federal statute directly creates the cause of action (e.g., Title IX, Sherman Antitrust Act).
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Essential Federal Ingredient Test (EFI) (Gunn, Smith): A "side door" approach with four elements (Grable):
- The case necessarily raises a federal law issue.
- The federal law issue is actually disputed.
- The federal law issue is substantial.
- Hearing the state law claims wouldn't disrupt the balance of federal/state court powers.
Diversity Jurisdiction (§1332)
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Article III, Section 2: Minimal diversity is sufficient (State Farm). The amount in controversy is irrelevant.
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28 U.S.C. §1332 (Amount in Controversy): Must exceed $75,000 (Coventry Sewage).
- St. Paul Mercury Test: "Good faith" assessment of the amount recoverable (objective and subjective). Legal certainty test used to assess amount. -Objective: A reasonable person's understanding of the potential recovery. -subjective: The plaintiff's actual belief about the potential recovery.
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Aggregation: Adding claims to reach the $75,000 threshold.
- Plaintiff's claims against a single defendant can be aggregated. -Multiple parties must have a common title or undivided interest for aggregation.
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Complete Diversity (Strawbridge): No plaintiff and defendant can be from the same state.
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Determining Citizenship:
- Natural Persons: Domicile at the time of filing the suit. To prove change: physical presence in a new state and the intent to stay indefinitely.
- Corporations (1332(c)(1)): Determined using the Nerve Center test. The place where the corporation is directed and controlled (usually corporate headquarters).
- Unincorporated Partnerships: Citizenship of any partner at the time of filing (Grupo v. Dataflux). Full party removal to fix diversity; not a member as per Grupo (Caterpillar).
- Aliens (Eze): Treated as a foreign citizen or resident depending on the situation.
Challenging Subject Matter Jurisdiction
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Direct Attack:
- Possible at any time before the appellate process is complete.
- Can be raised in federal district court by motion to dismiss (Rule 12(b)(1)).
- In federal court, SMJ deficiencies may be challenged at any time before final judgment in federal court (Grupo)
- In cases filed in state court that are later removed to federal court, SMJ challenges must be presented to the federal court.
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Collateral Attack:
- Generally not permitted in federal courts (Chicot County Drainage District).
- State courts may have a bit more flexibility on this matter (Kalb).
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Description
Test your understanding of federal question jurisdiction and subject matter jurisdiction in federal courts. This quiz covers key concepts from Article III and 28 U.S.C. §1331, including various tests for jurisdiction. Perfect for law students familiar with these critical legal principles.