Saturday, December 28, 2013

Ruhrgas AG v. Marathon Oil Co. case brief

Ruhrgas AG v. Marathon Oil Co. case brief summary
526 U.S. 574 (1999)

CASE SYNOPSIS
Defendant appealed a decision of the United States Court of Appeals for the Fifth Circuit, which vacated the panel of the court of appeals decision and held that district courts must decide issues of subject matter jurisdiction before personal jurisdiction issues.

CASE FACTS
Plaintiff corporations initiated an action against defendant petitioner in Texas state court for various business torts. Defendant removed the case to federal court on the basis of diversity of citizenship. Defendant moved to dismiss for lack of personal jurisdiction and plaintiff moved to remand the case to state court on the basis of lack of subject matter jurisdiction.

PROCEDURAL HISTORY
The district court granted defendant's motion to dismiss, and a panel of the court of appeals rejected defendant's basis for federal jurisdiction and remanded to state court. The court of appeals, en banc, vacated the panel's decision and held that subject matter jurisdiction must be decided before personal jurisdiction.

DISCUSSION

  • The Supreme Court, upon petitioner's writ of certiorari, reversed and remanded the lower court's holding. 
  • The Court held that a federal court might dismiss on the basis of either subject matter or personal jurisdiction, and that subject matter jurisdiction need not be determined prior to personal jurisdiction. 
  • Moreover, the Court reasoned that both subject matter and personal jurisdiction are needed in federal court, therefore it was not mandatory for a court to look at both types of jurisdiction.

CONCLUSION
Upon a writ of certiorari, the Supreme Court reversed and remanded the appellate court's decision where it held that a district court must first decide subject matter prior to personal jurisdiction. The Court reasoned that both subject matter and personal jurisdiction were needed for a federal court to hear a case, and therefore it was irrelevant whether a case was remanded on the basis of lack of subject matter or personal jurisdiction.


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