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Ankenbrandt v. Richards

Supreme Court of the United States · 1992 · Civil Procedure

Civil ProcedureDiversity JurisdictionAbstentionDomestic Relations Exceptiondiversity jurisdictiondomestic relations exceptiondivorcealimony

Facts

Carol Ankenbrandt, a Missouri citizen, sued on behalf of her daughters in federal district court against Jon Richards and Debra Kesler, Louisiana citizens. The complaint invoked 28 U.S.C. § 1332 and sought only monetary damages for alleged sexual and physical abuse of the children. Richards was the children's divorced father, and Kesler was his female companion. The suit did not seek a divorce, alimony, or child custody decree.

Issue

Does the domestic relations exception to diversity jurisdiction bar a federal tort action for damages between diverse parties when the suit does not seek a divorce, alimony, or child custody decree? If not, could the district court nonetheless abstain under Younger, or under any other abstention principle, on these facts?

Rule

The domestic relations exception is a statutory limitation on diversity jurisdiction that divests federal courts of power to issue divorce, alimony, and child custody decrees, but it does not bar ordinary tort actions for damages merely because the parties have a domestic relationship. Younger abstention is improper absent a pending state proceeding, and Burford abstention is inappropriate where the status of the domestic relationship has already been determined under state law and is irrelevant to the underlying tort claims.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Calder, a citizen of Oregon, sued her former husband, Evan Pike, a citizen of Nevada, in federal district court in Portland. She seeks only money damages for battery and false imprisonment allegedly committed during a post-divorce property exchange and does not ask the court to alter any family-court order.

Should the federal court dismiss for lack of subject-matter jurisdiction under the domestic relations exception?

Explanation. The majority held that the domestic relations exception is narrow. It divests federal courts of power to issue divorce, alimony, and child custody decrees, but it does not bar ordinary tort suits for money damages merely because the parties have or had a domestic relationship. Because Nina seeks only damages and no domestic-status decree, diversity jurisdiction is not excluded on this basis.