Ohio v. Wyandotte Chemicals Corp.

Supreme Court of the United States · 1971 · Federal Courts

Federal CourtsOriginal JurisdictionSupreme Court Discretionoriginal jurisdictionArticle III28 U.S.C. § 1251(b)(3)state versus citizens of another statealiens

Facts

Ohio sued Wyandotte Chemicals Corp., Dow Chemical Co., and Dow Chemical Company of Canada, Ltd., alleging that Wyandotte and Dow Canada dumped mercury into streams flowing into Lake Erie and that Dow America was jointly responsible for its subsidiary's acts. Ohio sought declarations of public nuisance, injunctive relief, mercury removal or funding for removal, and damages for harm to Lake Erie, wildlife, vegetation, and Ohio citizens. The defendants were citizens of other states or a foreign country, bringing the case within the textual scope of the Court's original jurisdiction. At the same time, multiple other governmental bodies were already regulating or studying the alleged pollution, including state agencies, a federal conference, and an international commission.

Issue

Whether the Supreme Court, although possessing original jurisdiction over Ohio's nuisance action against citizens of another state and a foreign corporation, should exercise that jurisdiction by granting leave to file the complaint. More specifically, the question was whether the Court may decline such jurisdiction when other forums and institutions are better suited to resolve the dispute.

Rule

As a general matter, the Supreme Court may decline to entertain a complaint brought by a State against the citizens of another State or country only where it can say with assurance that (1) declining jurisdiction would not disserve any of the principal policies underlying the Article III jurisdictional grant and (2) the practical reasons showing the Court is an inappropriate forum are consistent with limiting this aspect of the Court's original-jurisdiction function in light of its primary responsibilities as the final federal appellate court.

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

The State of Indiana asks the Supreme Court for leave to file an original action against Blue Harbor Plastics, a corporation incorporated and headquartered in Illinois, alleging chemical runoff from a plant near Joliet has damaged wetlands and fisheries in northwest Indiana. Indiana's complaint seeks an injunction, cleanup funding, and damages, and Indiana courts can obtain personal jurisdiction over the company under state long-arm law.

How should the Court most likely analyze whether to entertain the action?

Explanation. The majority recognized that the complaint falls within the Court's original jurisdiction, but held the Court may still decline to entertain such a state-versus-nonresident suit where it can say with assurance that declining will not disserve the principal Article III policies and practical reasons make the Court an inappropriate forum. The existence of an adequate state forum is central to that analysis. (Derived from Ohio v. Wyandotte Chemicals Corp. (1971).)