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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.
THIS was an appeal from a decree of the circuit court, for the district of Massachusetts, which dismissed the complainants' bill in chancery, for want of jurisdiction.
Some of the complainants were alleged to be citizens of the state of Massachusetts. The defendants were also stated to be citizens of the same state, excepting Curtiss, who was averred to be a citizen of the state of Vermont, and upon whom the subpoena was served in that state.
The question of jurisdiction was submitted to the court without argument, by P. B. Key, for the appellants, and Harper, for the appellees.
On a subsequent day,
MARSHALL, Ch. J. delivered the opinion of the court.
The court has considered this case, and is of opinion that the jurisdiction cannot be supported.
The words of the act of congress are, 'where an alien is a party; or the suit is between a citizen of a state where the suit is brought, and a citizen of another state.'
The court understands these expressions to mean that each distinct interest should be represented by persons, all of whom are entitled to sue, or may be sued, in the federal courts. That is, that where the interest is joint, each of the persons concerned in that interest must be competent to sue, or liable to be sued, in those courts.
But the court does not mean to give an opinion in the case where several parties represent several distinct interests, [7 U.S. 267, 268] and some of those parties are, and others are not, competent to sue, or liable to be sued, in the courts of the United States.
Decree affirmed.
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Citation: 7 U.S. 267
Decided: February 01, 1806
Court: United States Supreme Court
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