Facts
|
-Capron (P) sued Van Noorden (D) in federal district court
(negligence: “trespass on the case”).
-Here there was no “Federal Issue.” -Complaint did not establish that either of the parties was an alien or a citizen of North Carolina or a citizen of another state. -The case could only be heard in federal court if it were based on diversity. -The court heard the case nevertheless and entered judgment in favor of Van Noorden. -Capron appealed on the basis that the court did not have jurisdiction because diversity had not been established. |
Issue
|
Will the federal courts throw out a case on appeal for
lack of subject matter jurisdiction?
|
Holding
|
Yes.
-The Supreme Court overturned the verdict in favor of D. This doesn’t mean that D won, simply that the trial never occurred. |
Rules
|
-A party cannot consent to jurisdiction in a federal court
if no actual diversity exists.
-Challenges to subject matter jurisdiction can be raised at any time prior to final judgment. -Federal courts are courts of limited jurisdiction and here there was no jurisdiction upon which the court could take the case. - This limitation is imposed on the court by the Constitution and cannot be waived by the parties. -A federal court must dismiss a case for lack of subject matter jurisdiction even if the matter is raised for the first time on appeal. Jurisdiction is a matter that can be raised sua sponte by the trial court or court of appeals. |
Analysis
|
Because P’s case lacked the proper subject matter
jurisdiction for Federal Court, the case was thrown out.
|
Case briefs for law students, lawyers, and others researching case law. I created many of these briefs in law school and periodically update them from time to time. My goal has been to build a one stop resource center for law students!
Tuesday, September 18, 2012
Capron v. Van Noorden case brief (6 US 126, 2 Cranch 126 (1804).)
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