Hepburn & Dundas v. Ellzey

Supreme Court of the United States · 1805 · Federal Courts

Federal CourtsDiversity Jurisdictiondiversity jurisdictionDistrict of Columbiastate citizenshipArticle III terminologyJudiciary Actconstitutional interpretation

Facts

The plaintiffs were residents of the District of Columbia and brought an action in the federal circuit court for the District of Virginia. Federal jurisdiction depended on the congressional act giving circuit courts jurisdiction over cases between a citizen of the state where suit is brought and a citizen of another state. The plaintiffs argued that Columbia was a distinct political society and therefore a state. The jurisdictional question therefore turned on whether Columbia counted as a state within the meaning of the Constitution and the act of Congress.

Issue

Whether residents of the District of Columbia may sue in the federal circuit court for the District of Virginia under the statutory grant of jurisdiction over suits between a citizen of the state where the suit is brought and a citizen of another state. More specifically, the question was whether the District of Columbia is a 'state' within the meaning of that grant.

Rule

When Congress uses the word 'state' in the jurisdictional statute by reference to the Constitution, the term means a member of the Union as contemplated by the Constitution. Therefore, the District of Columbia is not a 'state' for purposes of the circuit courts' diversity jurisdiction.

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

Nadia Brooks lives in the District of Columbia and files a contract action in the federal circuit court sitting in Maryland against Evan Cole, a citizen of Maryland. Nadia argues that she belongs to a different political community than Maryland and therefore qualifies as a citizen of another state.

Should the federal circuit court exercise jurisdiction under the statute granting jurisdiction over suits between a citizen of the state where suit is brought and a citizen of another state?

Explanation. The controlling rule is that when the jurisdictional statute uses the word "state" in reference to the Constitution, it means a member of the Union as contemplated by the Constitution. Although the District of Columbia may be a distinct political society in a broader sense, it is not a "state" for this statutory grant. Therefore Nadia is not a citizen of another state within the meaning of the statute, and the circuit court lacks jurisdiction. (Derived from Hepburn & Dundas v. Ellzey (1805).)