The Oyez Project: Judicial Power Issues - Jurisdiction or Authority of Federal District Courts Decisions

Affronti v. United States

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American National Red Cross v. S.G. and A.E.

Does the "sue and be sued" provision in the Red Cross' charter confer original jurisdiction on federal courts over all cases to which the Red Cross is a party?

Yes. A congressional charter's "sue and be sued" provision confers federal-court jurisdiction if, but only if, it specifically mentions the federal courts. The Red Cross Charter provision does specifically mention the federal courts. This holding leaves the jurisdiction of the federal courts well within the Article III limits, because the Court has consistently held that Article III's "arising under" jurisdiction is broad enough to authorize Congress to confer federal-court jurisdiction over actions involving federally chartered corporations.

Arkansas v. Farm Credit Services

Do Production Credit Associations fall within the exception in the Tax Injunction Act created by Department of Employment v. United States when they sue by themselves?

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that Production Credit Associations are not included within the judicial exception to the Act by virtue of their designation as instrumentalities of the United States alone. Therefore, the Court continued, PCA's may not sue in federal court for an injunction against state taxation without the United States as co-plaintiff. "The Tax Injunction Act is grounded in the need of States to administer their fiscal affairs without undue interference from federal courts," wrote Justice Kennedy, "[a]s all parties concede, respondents have a 'speedy, plain, and efficient remedy' in state court."

Auto Workers v. Scofield

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Behrens v. Pelletier

Does a defendant's immediate appeal of an unfavorable qualified-immunity ruling on his motion to dismiss deprive the court of appeals of jurisdiction over a second appeal, also based on qualified immunity, immediately following denial of summary judgment?

No. In a 7-2 opinion delivered by Justice Antonin Scalia, the Court held that the court of appeals was not deprived of jurisdiction. The Court reasoned that the agent was not limited in such circumstances to one interlocutory appeal from a denial of qualified immunity. Justice Scalia wrote that, "an order rejecting the defense of qualified immunity at either the dismissal stage or the summary judgment stage is a 'final' judgment subject to immediate appeal." In a dissent joined by Justice John Paul Stevens, Justice Stephen G. Breyer wrote, in such cases, "the law normally permits a single interlocutory appeal, and not more than one such appeal."

Bell v. Thompson

After the U.S. Supreme Court had denied certiorari and a petition for rehearing to a death-row prisoner's case, did the Sixth Circuit abuse its discretion by withholding its mandate in the case for more than five months without entering a formal order?

Yes. In a 5-4 opinion delivered by Justice Anthony Kennedy, the Court held that the Sixth Circuit abused its discretion by withholding its mandate and not releasing its amended opinion for more than five months after the Supreme Court's final say in the case. The Sixth Circuit cost the state and the parties significant time and resources by not providing notification that it was reconsidering its decision. Further, the Sixth Circuit had the opportunity at the rehearing stage to consider the same mental health arguments it later adopted. Moreover, the evidence and its ommission did not warrant the court's "extraordinary departure from standard procedures." By withholding its mandate for months, the Court said, the Sixth Circuit failed to give the "appropriate level of respect" to Tennessee's judgment that Thompson deserved death. Notably, the Court declined to consider the scope of the appellate courts' Federal Appellate Procedure 41 authority to stay a mandate following a denial of certioarari.

Beneficial National Bank v. Anderson

Does the NBA require that any suits involving charges of excessive interest be heard in federal rather than state court?

Yes. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that the National Bank Act preempted the state-law claim and provided the exclusive cause of action for usury claims against national banks. Thus, the claim arose under federal law. The Court reasoned that the provisions of the Act create a federal remedy for overcharges that is exclusive, even when a state complainant relies entirely on state law. "Because [sections of the Act] provide the exclusive cause of action for such claims, there is, in short, no such thing as a state-law claim of usury against a national bank," wrote Justice Stevens. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented.

Board Of Governors Of The Federal Reserve System v. MCorp Financial, Inc.

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Bowen v. Massachusetts

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Breuer v. Jim's Concrete

In providing for suits under the FLSA, did Congress bar removal of such actions from state to federal court?

No. In a unanimous opinion delivered David H. Souter, the Court held that the FLSA does not bar removal of a suit from state to federal court, thus Breuer's case was properly removed under section 1441. The Court reasoned that nothing on the face of the FLSA looked like an express prohibition of removal, there being no mention of removal, let alone of prohibition, given that word "maintain" and its bearing on removal was ambiguous at best. Rejecting all of Breuer's arguments, the Court noted that numerous other statutes provided indisputable prohibitions of removal, which demonstrated Congress's intent to give plaintiffs an absolute choice of forum in unmistakable terms.

Brown v. Chote

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California v. Deep Sea Research

Does the Eleventh Amendment, limiting federal jurisdiction over maritime matters, bar a federal court's jurisdiction over an admiralty property claim where the property itself is not within the State's possession?

No. In a unanimous opinion the Court held that while precedent interpreting the Eleventh Amendment supports a limited bar on federal admiralty jurisdiction disputes centering on people or property that is in a state's possession, the same does not apply when the concerned state lacks possession of the disputed maritime property. The Court noted that in this case, neither the federal government nor the State of California had possession of the Brother Jonathan and, therefore, the Eleventh Amendment's jurisdictional ban was inapplicable. The Court concluded by noting that since several outstanding insurance claims were made on the Brother Jonathan at the time of her sinking, the question of whether the wreck was truly "abandoned" remained unresolved. Accordingly, the Court remanded the matter for further consideration.

Carden v. Arkoma Associates

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Carnegie-Mellon Univ. v. Cohill

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Caterpillar Inc. v. Lewis

Is the absence of complete diversity at the time of removal from state to federal court fatal to federal adjudication even when there is complete diversity at the time of judgment?

No. A failure to remand a case improperly removed is not fatal to federal adjudication of the case so long as federal jurisdictional requirements are met at the time judgment is entered. When a diversity case has been tried in federal court under state rules of decision, the importance of finality, efficiency and economy in judicial determinations becomes decisive. To remand this case for a new trial after several years of litigation, despite the fact that the jurisdictional defect had been cured by the time of judgment, would be to impose an exorbitant cost on the judicial system.

Catholic Conf. v. Abortion Rights Mobilization

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Celotex Corp. v. Edwards Et ux.

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Chambers v. Nasco, Inc.

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Chapman v. Houston Welfare Rights Org.

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Christianson v. Colt Industries Operating Corp.

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City Of Kenosha v. Bruno

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Clinton v. Goldsmith

Does the Court of Appeals for the Armed Forces have the jurisdiction under the All Writs Act to enjoin the President and various military officials from dropping a convict from the rolls of the Air Force?

No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that because the Court of Appeals for the Armed Forces' resort to the All Writs Act was neither in aid of its strictly circumscribed jurisdiction to review court-martial findings and sentences nor "necessary or appropriate" in light of a servicemember's alternative opportunities to seek relief, that court lacked jurisdiction to issue an injunction against dropping Goldsmith from the Air Force rolls. Justice Souter's opinion emphasized the alternative avenues of relief available to Goldsmith.

Clothing Workers v. Richman Bros.

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D.C. Court Of Appeals v. Feldman

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Dept. Of Employment v. U.S.

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Dole Food Co. v. Patrickson

May a corporate subsidiary claim instrumentality status where the foreign state does not own a majority of its shares but does own a majority of the shares of a corporate parent one or more tiers above the subsidiary? Is a corporation's instrumentality status defined as of the time an alleged tort or other actionable wrong occurred?

No and no. In an opinion delivered by Justice Anthony M. Kennedy, the Court held, 7-2, that a foreign state must itself own a majority of the shares of a corporation if the corporation is to be deemed an instrumentality of the state under the provisions of the FSIA and, 9-0, that instrumentality status is determined at the time of the filing of the complaint. The Court reasoned that, as indirect subsidiaries of Israel, the Dead Sea Companies cannot come within the statutory language granting instrumentality status and that only direct ownership satisfies the statutory requirement. Concurring in part and dissenting in part, Justice Stephen G. Breyer, joined by Justice Sandra Day O'Connor, argued that the language "other ownership interest...owned by a foreign state," covers a foreign state's legal interest in a corporate subsidiary, where that interest consists of the foreign state's ownership of a corporate parent that owns the shares of the subsidiary. As Dole did not seek review of the Court of Appeals' decision, the writ of certiorari in 01-593 was dismissed.

Dow Chemical Company v. Stephenson

Does the 1984 Agent Orange settlement preclude plaintiffs, who allege that they were inadequately represented in the prior litigation, from asserting claims?

An equally divided Court affirmed in part and vacated and remanded in part. In a per curiam opinion, the Court affirmed the judgment of Court of Appeals with respect to Stephenson and vacated and remanded the judgment of Court of Appeals with respect to Isaacson for further consideration in light of Syngenta Crop Protection, Inc. v. Henson, 537 U.S. 28 (2002). Justice John Paul Stevens took no part in the consideration or decision of this case.

Elder v. Holloway

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Empire HealthChoice Assurance v. McVeigh

Under the Federal Employees Health Benefits Act of 1959, are suits brought by insurers against beneficiaries to recoup medical expenses heard in federal or state court?

In a 5-to-4 decision authored by Justice Ruth Bader Ginsburg, the Court held that jurisdiction for this case lay in state court. Justice Ginsburg pointed out that while FEHBA stated that any claims against the United States would be heard in federal district court, it made no provisions for suits brought by insurers seeking to recoup medical expenses from private beneficiaries. Absent that specific provision, a significant conflict with an identifiable federal interest, or the need to resolve a substantial question of federal law in order to establish the insurer's right to recovery, there was no reason to depart from the ordinarily-governing state law. Justices Breyer, Kennedy, Souter and Alito dissented.

Exxon Mobil v. Saudi Basic Industries

Did the Rooker-Feldman doctrine bar a suit that was filed in federal district court before a state court ruled on the petitioner's related claims?

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the the Third Circuit "misperceived the narrow ground occupied by Rooker-Feldman." That doctrine was confined to cases brought by state-court losers complaining of state-court judgments made before the federal district court proceedings began and inviting district court rejection of those judgments. In this case, ExxonMobil's federal suit was filed before any state-court judgment and had not sought the review of any such judgment. Rather, the company had sought to protect itself in the event it lost in state court on grounds that might not have precluded relief in federal court. Moreover, in cases of parallel state and federal litigation, Rooker-Feldman was not triggered simply by the entry of a state court judgment. Properly invoked concurrent jurisdiction did not vanish if a state court reached judgment on the same or a related question while the case remained before a federal district court. Rooker-Feldman did not otherwise override or supplant preclusion doctrine or add to the circumscribed doctrines allowing federal courts to dismiss proceedings in deference to state-court actions.

Florida Dept. of State v. Treasure Salvors, Inc.

Does a district court's issuance of a property seizure warrant against a state violate the Eleventh Amendment?

No. In a plurality opinion, the Court first held that while a state enjoys limited immunity from federal process under the Eleventh Amendment, its officers do not. In the present case, the seizure warrant was filed against Florida's officers in the Archives. The Archive officers, although acting in official state capacity and defended by state attorneys, are not immune as the state itself may be from having to pay a judgment against them. Moreover, the Court found that although a profit sharing contract existed between Treasure and Archives, it did not justify Archive's refusal to surrender ownership over the artifacts pursuant to a federal warrant. Finally, the Court ruled that the district court lacked jurisdiction to adjudicate Florida's interest in the artifacts because these materials were held in a different district court's jurisdiction. As such, the decision was reversed in part and remanded as to its jurisdictional violations.

Franchise Tax Bd. v. Laborers Vacation Trust

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Fslic v. Ticktin

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Gasperini v. Center for Humanities Inc.

Does New York's law that empowers appellate courts to review the size of jury's awards conflict with the Seventh Amendment's guarantee of jury trials in civil cases?

No. In a 5-4 plurality decision, authored by Justice Ruth Bader Ginsburg, the Court ruled that New York's law controlling compensation awards for excessiveness or inadequacy can be given effect, without detriment to the Seventh Amendment, if the review standard is applied by the federal trial court judge, with appellate control of the trial court's ruling confined to "abuse of discretion."

Grupo Dataflux v. Atlas Global Group, L.P.

If a suit is filed in federal court without the diversity necessary to establish jurisdiction, but the citizenship of one of the parties changes before the case begins so that diversity is present, should the court ignore the filing error?

No. In a 5-to-4 decision written by Justice Antonin Scalia, the Court ruled that allowing diversity jurisdiction to change after a case is filed would create uncertainty and expensive litigation that dealt with jurisdiction rather than the merits of the case. "Uncertainty regarding the question of jurisdiction is particularly undesirable, and collateral litigation on the point particularly wasteful," wrote Justice Scalia. "The stability provided by our time tested rule (of requiring diversity at the time of filing) weighs heavily against the approval of any new deviation."

Grupo Mexicano de Desarrollo v. Alliance Bond Fund

Does the District Court, in an action for monetary damages, have the authority to issue a preliminary injunction preventing the defendant from transferring assets in which no lien or equitable interest is claimed?

No. In an opinion delivered by Justice Antonin Scalia, the Court held that the District Court lacked the authority to issue a preliminary injunction preventing defendants being sued by creditors from disposing of their assets pending adjudication of the creditor's contract claim for monetary damages because such a remedy was historically unavailable from a court of equity. Allowing federal courts to grant creditors such injunctions "could radically alter the balance between debtors' and creditors' rights," Justice Scalia wrote for the Court, and "might induce creditors to engage in a race to the courthouse...which might prove financially fatal to the struggling debtor."

Guam v. Olsen

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Hoffmann-LaRoche Inc. v. Sperling

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Holmes Group, Inc. v. Vornado Air Circulation System

Does the Court of Appeals for the Federal Circuit have appellate jurisdiction over a case in which the complaint does not allege a claim arising under federal patent law, but the answer contains a patent-law counterclaim?

No. In a 9-0 opinion delivered by Justice Antonin Scalia, the Court held that the appellate could not assert jurisdiction over such a case. Noting that the Court of Appeals for the Federal Circuit's jurisdiction is fixed and turns on whether an action is one arising under federal patent law, the Court reasoned that because the complaint asserted no claim arising under patent law, the court erred in asserting jurisdiction over the appeal. "By limiting the Federal Circuit's jurisdiction to cases in which district courts would have jurisdiction...Congress referred to a well-established body of law that requires courts to consider whether a patent-law claim appears on the face of the plaintiff's...complaint. Because [Holmes's] complaint did not include any claim based on patent law, we vacate the judgment of the Federal Circuit," wrote Justice Scalia.

Horton v. Liberty Mut. Ins. Co.

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Icicle Seafoods, Inc. v. Worthington

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Idlewild Liquor Corp. v. Epstein

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Jaffke v. Dunham

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Jean v. Nelson

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Jerome B. Grubart Inc. v. Great Lakes Dredge and Dock

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Kircher v. Putnam Funds Trust

Can a federal district court's decision to send a case back to state court because its removal to federal court was not required by the Security Litigation Uniform Standards Act be reviewed by a circuit court of appeals under 28 U.S.C. 1447(d)?

No. In an opinion by Justice David Souter, the Supreme Court unanimously held that the district court's decision had been jurisdictional and that the appeals court's review was therefore barred by 1447(d). Quoting Briscoe v. Bell, 432 U.S. 404, Justice Souter wrote that "where the order is based on one of the [grounds enumerated in 28 U.S.C. 1447(c)], review is unavailable no matter how plain the legal error in ordering the remand."

Kokkonen v. Guardian Life Insurance Company Of America

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Kramer v. Caribbean Mills

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La Buy v. Howes Leather Co.

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Labor Board v. Warren Company

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Lewis v. Lewis & Clark Marine

Did a District Court abuse its discretion when it dissolved an injunction under the Limitation of Liability Act, which prevented a seaman from suing a vessel owner in state court for personal injuries sustained aboard the vessel?

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that because state courts may adjudicate claims like Lewis' against vessel owners so long as the owner's right to seek limitation of liability is protected, the Court of Appeals erred in reversing the District Court's decision to dissolve the injunction. Writing for the Court, Justice O'Conner rejected the respondent's proposal to make "run of the mill personal injury actions involving vessels a matter of exclusive federal jurisdiction except where the claimant happens to seek a jury trial."

Lexecon, Inc. v. Milberg Weiss Bershad Hynes and Lerach

May a federal district court conducting "pretrial proceedings" under 28 USC section 1407(a) invoke section 1404(a) to assign a transferred case to itself for trial?

No. In an opinion delivered by Justice David H. Souter, the Court held that a district court conducting pretrial proceedings pursuant to section 1407(a) has no authority to invoke section 1404(a) to assign a transferred case to itself for trial. The Court noted that the Panel's section 1407(a) instructions are crouched in the word "shall," which "creates an obligation impervious to judicial discretion." Justice Souter wrote for the Court that, "the straightforward language imposing the Panel's responsibility to remand... bars recognizing any self-assignment power in a transferee court." The opinion was unanimous except insofar as Justice Antonin Scalia did not join Part II-C.

Liberty Mutual Ins. Co. v. Wetzel

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Lincoln Property Co. v. Roche

Could defendants remove an action on the basis of diversity of citizenship if there was complete diversity between all named plaintiffs and all named defendants, and no defendant was a citizen of the forum state?

Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Lincoln did not need to negate the existence of a potential defendant whose presence in the action would destroy diversity. To remove the suit to federal court, Lincoln only needed to show complete diversity between all named plaintiffs and all named defendants.

Malone v. Bowdoin

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Marshall v. Marshall

(1) What is the scope of the "probate exception" to federal jurisdiction? (2) Does the exception apply to cases that do not directly involve the administration of a will or estate?

In a unanimous decision authored by Justice Ruth Bader Ginsburg, the Court reversed the Ninth Circuit and held that the probate exception did not apply. The Court's opinion stressed the "distinctly limited scope" of the exception. The Justices explained that while the probate exception was intended to preserve state-court control over wills and estates, it does not remove from federal jurisdiction every suit arising out of probate matters. In Ms. Marshall's case, her claim did not directly involve the validation of J. Howard Marshall's will or the administration of his estate, so the exception did not apply and the federal courts had jurisdiction.

Mathews v. Weber

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Miner v. Atlass

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Missouri v. Jenkins

Did the court order to increase property taxes violate Article III, the Tenth Amendment, or principles of federal/state comity?

The Court held that the District Court "abused its discretion" by imposing a specific tax increase. The Court also held, however, that the modifications of the District Court's order made by the Court of Appeals satisfied "equitable and constitutional principles governing the District Court's power...." The majority found that court orders directing local governments to levy their own taxes were "plainly" judicial acts within the powers of federal courts. When a constitutional justification existed, courts had the authority to order tax increases despite statutory limitations. The Court reasoned that "[t]o hold otherwise would fail to take account of the obligations of local governments, under the Supremacy Clause, to fulfill the requirements that the Constitution imposes on them."

N. H. Fire Ins. Co. v. Scanlon

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National Farmers Union Ins. Cos. v. Crow Tribe

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Newman-Green, Inc. v. Alfonzo-Larrain

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Nguyen v. United States

Did a panel of the Court of Appeals consisting of two Article III judges and one Article IV judge have the authority to decide the appeals of two defendants convicted on federal narcotics charges in the District Court of Guam?

No. In a 5-4 opinion delivered by Justice John Paul Stevens, the Court held that the Court of Appeals panel did not have the authority to decide Nguyen and Phan's appeals. The Court reasoned that the territorial judge was precluded from designation to the panel and thus the defendants' appeals required reconsideration by a properly constituted panel. The Court found that the statutory and constitutional provisions governing the creation and tenure of territorial judges were distinct from those for district court judges and that the territorial district court was not constituted pursuant to the chapter required to meet the definition of a district court. Chief Justice William H. Rehnquist, joined by Justices Antonin Scalia, Ruth Bader Ginsburg, and Stephen G. Breyer, dissented, arguing that neither Nguyen nor Phan showed that the error seriously affected the judicial proceedings.

Pa. Bureau Of Correction v. U.S. Marshals

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Pasadena City Bd. Of Education v. Spangler

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Petrowski v. Hawkeye-Security Co.

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Plumbers & Pipefitters v. Plumbers & Pipefitters

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Republic of Argentina v. Weltover, Inc.

Was the Republic of Argentina's default on certain bonds an act taken "in connection with a commercial activity" that had a "direct effect in the United States" so as to subject Argentina to suit in an American court under the Foreign Sovereign Immunities Act of 1976?

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the District Court properly asserted jurisdiction under the FSIA. The Court reasoned that the issuance of the Bonods was a "commercial activity" and that the rescheduling of the maturity dates on those instruments was taken "in connection with" that activity because Argentina had acted as a private player within a market and not as a regulator of that market. Moreover, the Court concluded that the unilateral rescheduling of the Bonods had a "direct effect in the United States" because Argentina had designated their accounts in New York as the place of payment and had made some interest payments into those accounts before announcing that it was rescheduling the payments.

Roell v. Withrow

Can consent, under the Federal Magistrate Act of 1979, be inferred from a party's conduct during litigation?

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that consent to a magistrate judge's designation can be inferred from a party's conduct during litigation. Distinguishing between full and part-time magistrate judges, the Court reasoned that the "unadorned references" regarding the consent of the parties and full-time magistrate judges provided for jurisdiction as long as the parties voluntarily consented. "[The two staff members'] general appearances before the Magistrate Judge, after they had been told of their right to be tried by a district judge, supply the consent necessary for the Magistrate Judge's 'civil jurisdiction,'" wrote Justice Souter.

Ruhrgas AG v. Marathon Oil Co.

Is a federal district court barred from dismissing a removed case for lack of personal jurisdiction without first deciding its subject-matter jurisdiction?

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that in cases removed from a state court to federal court there is "no unyielding jurisdictional hierarchy requiring the federal court to adjudicate subject-matter jurisdiction before considering a challenge to personal jurisdiction." Customarily, however, a federal court would first resolve doubts about its jurisdiction over the subject matter. Justice Ginsburg wrote, "[w]here...a district court has before it a straightforward personal jurisdiction issue presenting no complex question of state law, and the alleged defect in subject matter jurisdiction raises a difficult and novel question, the court does not abuse its discretion by turning directly to personal jurisdiction."

Salve Regina College v. Russell

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Spallone v. United States

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Stern v. South Chester Tube Co.

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Swint v. Chambers County Commission

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Syngenta Crop Protection, Inc. v. Henson

Does the All Writs Act give a federal district court the authority to remove a state-court case in order to prevent the frustration of orders the federal court has previously issued?

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the All Writs Act does not provide removal jurisdiction. The Court reasoned that, because the general removal statute requires that a federal court have original jurisdiction over an action in order for it to be removed from a state court, the All Writs Act, alone or in combination with the existence of ancillary jurisdiction in a federal court, is not a substitute for that requirement. Justice John Paul Stevens concurred.

Textron Lycoming v. United Automobile Workers

Does section 301 of the Labor-Management Relations Act permit a union to sue in federal court to declare a collective bargaining agreement voidable in the absence of any alleged violation of the agreement?

No. In an opinion delivered by Justice Antonin Scalia, the Court held that neither it nor the lower federal courts have subject-matter jurisdiction under section 301 because the Union's complaint alleged no violation of the collective-bargaining agreement. "Suits for violation of contracts" under [section 301(a)] are not suits that claim a contract is invalid, but suits that claim a contract has been violated, wrote Justice Scalia. Justices John Paul Stevens and Stephen G. Breyer filed concurring opinions.

Thermtron Products, Inc., v. Hermansdorfer

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Things Remembered, Inc. v. Petrarca

May a federal court of appeals review a district court order remanding a bankruptcy case to state court on grounds of untimely removal?

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that if an order remands a removed bankruptcy case to state court because of a timely raised defect in removal procedure or lack of subject-matter jurisdiction, a court of appeals lacks jurisdiction to review the order under the provisions of the general federal removal statute. The Court reasoned that the general removal statute bars appellate review of any order remanding a case to the State court from which it was removed so that only remands based on the grounds recognized by the statute, such as a timely raised defect in removal procedure or lack of subject-matter jurisdiction, are immune from review under the statute.

Thunder Basin Coal Co. v. Reich, Secretary Of Labor

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Tidewater Oil Co. v. United States

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United States v. Beggerly

Do federal courts lack jurisdiction over action to reopen a settlement quieting land title in the Federal Government either under Rule 60(b) of Federal Rules of Civil Procedure as an independent action or under Quiet Title Act?

Yes. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Court of Appeals erred in concluding that this was a sufficient basis to justify reopening the judgment. "[A]n independent action should be available only to prevent a grave miscarriage of justice," wrote Chief Justice Rehnquist, "it should be obvious that [the Beggerlys'] allegations do not nearly approach this demanding standard." The Court also concluded that the Court of Appeals extension of the Quiet Title Act's statutory period by equitable tolling was unwarranted, given its generous nature. Justice John Paul Stevens wrote a concurring opinion.

United States v. Fruehauf

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United States v. Hohri

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Wachovia Bank v. Schmidt

For the purposes of federal diversity jurisdiction, is a national bank "located" in every state in which it maintains a branch office?

No. In an 8-0 decision authored by Justice Ruth Bader Ginsburg, the Court ruled that a national bank is "located" in, and therefore a "citizen" of, only the state in which its main office is located. Looking to the history of Congress's diversity jurisdiction statutes, the Court concluded that the word "located" need not be interpreted to mean any state where a bank has a physical presence. Furthermore, the Court ruled that the Fourth Circuit had erred in drawing a distinction between the words "located" and "established": "the Congress may well have comprehended the words 'located' and 'established,' as used in [Section] 1348, as synonymous terms." Justice Thomas took no part in the decision of the case.

Will v. Calvert Fire Ins. Co.

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Wilton v. Seven Falls Co.

Does the exceptional circumstances test govern a district court's decision to stay a declaratory judgment action during the pendency of parallel state court proceedings? Should a court of appeals evaluate a district court's decision to do so under an abuse of discretion standard of review?

No and yes. In a 8-0 opinion delivered by Justice Sandra Day O'Connor, the Court held that the discretionary standard of Brillhart v. Excess Ins. Co. of America, 316 U.S. 491, governs a district court's decision to stay a declaratory judgment action during the pendency of parallel state court proceedings and that a district courts' decisions about the propriety of hearing declaratory judgment actions should be reviewed for abuse of discretion. The Court also concluded that the District Court acted within its bounds in staying the declaratory relief action in this case, since parallel proceedings, presenting an opportunity for the ventilation of the same state law issues, were underway in state court. Justice Stephen G. Breyer did not participate.

Wisconsin Department of Corrections v. Schacht

May a State and its actors as defendants in a state-court suit, with claims arising under federal law, remove the case to federal court when some claims are subject to the Eleventh Amendment doctrine of sovereign immunity?

Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that a State's claim of an Eleventh Amendment bar to a plaintiff's claims against the state places those claims beyond the power of the federal courts to decide, but that the State may remove the case to a federal court and that the court can decide the nonbarred claims. "A State's proper assertion of an Eleventh Amendment bar after removal means that the federal court cannot hear the barred claim. But that circumstance does not destroy removal jurisdiction over the remaining claims in the case before us. A federal court can proceed to hear those other claims, and the District Court did not err in doing so," concluded Justice Breyer. Justice Anthony M. Kennedy wrote a concurring opinion.