Tuesday, September 18, 2012

Capron v. Van Noorden case brief (6 US 126, 2 Cranch 126 (1804).)


 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.

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