STRAWBRIDGE v. CURTISS , 7 U.S. 267 (1806)

Written with the help of AI | Legally Reviewed by Balrina Ahluwalia, Esq. | Last updated October 1, 2024

In Strawbridge v. Curtiss, the Supreme Court established an important rule for determining federal court jurisdiction in cases involving multiple parties.

The landmark 1806 case involved a group of plaintiffs from Massachusetts. They sued a group of defendants in federal court. Most of the defendants were also from Massachusetts, but one (Curtiss) was from Vermont.

The federal court dismissed the case for lack of jurisdiction. At the time, federal courts could only hear cases between citizens of different states or those involving foreign citizens. This is called diversity jurisdiction.

The Supreme Court ultimately heard the case.

The High Court reviewed the Judiciary Act of 1789, which allows federal courts to hear cases between citizens of different states. It had to interpret the law and decide if partial diversity (where only some parties are from different states) allowed federal courts to take a case.

The Court determined it wasn’t.

It held that there must be complete diversity for a federal court to have diversity jurisdiction. This meant that everyone on one side of the case must be from a different state than everyone on the other side.

In other words, for cases with multiple plaintiffs or defendants, federal diversity jurisdiction requires that every plaintiff is from a different state than every defendant. No plaintiff can be from the same state as any defendant.

This came to be known as the "complete diversity" rule.

In the case at hand, most of the litigants were from Massachusetts. Only one was from a different state. So, the Court determined the federal court didn’t have diversity jurisdiction to hear the case because complete diversity wasn’t present.

Accordingly, it affirmed the lower court.

The Strawbridge decision significantly impacted federal court jurisdiction, making it more difficult for cases with multiple parties to be heard in federal courts. The ruling helped define the boundaries between state and federal courts. The "complete diversity" rule remains important for determining federal court jurisdiction today.