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Strawbridge v. Curtiss

Supreme Court of the United States · 1806 · Civil Procedure

Civil Procedurediversity jurisdictioncomplete diversitysubject matter jurisdictiondiversity jurisdictioncomplete diversityjoint interestsubject matter jurisdiction

Facts

The opinion provides only limited facts and focuses on jurisdiction. The case involved multiple parties and raised whether the federal courts could exercise jurisdiction under the statutory language covering suits between a citizen of the state where the suit is brought and a citizen of another state. The Court specifically addressed the situation in which parties shared a joint interest. The Court did not describe the underlying merits and treated the case as turning on whether all persons concerned in that joint interest were competent to sue or be sued in federal court.

Issue

Whether federal jurisdiction under the Act of Congress exists when there are multiple parties sharing a joint interest and not every person concerned in that interest is competent to sue, or liable to be sued, in the federal courts.

Rule

Under the statutory language authorizing suits where an alien is a party or where the suit is between a citizen of the state where the suit is brought and a citizen of another state, each distinct interest must be represented by persons all of whom are entitled to sue, or may be sued, in the federal courts. Where the interest is joint, each person concerned in that interest must be competent to sue, or liable to be sued, in those courts.

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

Nora Bell and Ethan Pike, both claiming a single joint right under one contract, file suit in federal court in Ohio against Lydia Marsh, a citizen of Michigan. Nora is a citizen of Ohio, but Ethan is also a citizen of Michigan.

Under the governing rule, is statutory diversity jurisdiction properly supported?

Explanation. The majority read the statute to require that each distinct interest be represented by persons all of whom are entitled to sue or may be sued in federal court. Where the interest is joint, each person concerned in that joint interest must independently satisfy the statutory citizenship requirement. Because one of the joint plaintiffs is a citizen of the same state as the defendant, jurisdiction fails.