Friday, December 27, 2013

Bell v. Hood case brief

Bell v. Hood case brief summary
327 U.S. 678 (1946)

CASE SYNOPSIS
Petitioners sought certiorari review of a judgment from the United States Court of Appeals for the Ninth Circuit, which affirmed the dismissal of petitioners' lawsuit alleging that respondent Federal Bureau of Investigation (FBI) agents had violated their rights under U.S. Constitutional amends.IV and V, on the ground that federal jurisdiction over the action pursuant to 28 U.S.C.S. § 41(1) was lacking.

CASE FACTS
Petitioners' complaint asserted that the FBI agents violated their constitutional rights to be free from unauthorized and unjustified imprisonment and from unreasonable searches and seizures. Petitioners claimed damages from the invasion of their rights, relying on federal question jurisdiction. The court of appeals affirmed the trial court's dismissal for lack of subject matter jurisdiction under 28 U.S.C.S. § 41(1).

DISCUSSION
  • On certiorari review, the United States Supreme Court and noted that, despite the agents' claim that the complaint actually asserted a state law action for trespass, the complaint was drawn to seek recovery directly under the United States Constitution, and such an assertion required the district court to entertain the suit. 
  • There was no indication that petitioners' constitutional claims were either made solely to obtain jurisdiction or were wholly frivolous to justify dismissal on jurisdictional grounds. 
  • Whether petitioners could recover monetary judgments against the agents for alleged constitutional violations was an issue of law that the district court had jurisdiction to consider.

CONCLUSION
The Court reversed the trial court's judgment dismissing petitioners' suit on jurisdictional grounds because petitioners' complaint clearly sought recovery under the Constitution, and there was no indication petitioners' claims were made solely for jurisdictional purposes or were frivolous.

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