Federal Question Jurisdiction under ederal Courts
Federal Question Jurisdiction under Federal Courts
1. What is Federal Question Jurisdiction?
Federal question jurisdiction refers to the authority of federal courts to hear cases that arise under the Constitution, laws, or treaties of the United States. It is a primary basis for federal court jurisdiction, codified in 28 U.S.C. § 1331, which states:
“The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.”
2. The "Well-Pleaded Complaint" Rule
To establish federal question jurisdiction, the federal question must appear on the face of the plaintiff’s properly pleaded complaint. This means the plaintiff’s claim must be based on federal law, not merely anticipate a federal defense.
3. Landmark Cases on Federal Question Jurisdiction
a) Louisville & Nashville Railroad Co. v. Mottley, 211 U.S. 149 (1908)
Facts:
The Mottleys had tickets for free lifetime passage on the railroad, but Congress later passed a law prohibiting free passes. They sued the railroad, claiming breach of contract, anticipating the railroad would assert the new law as a defense.
Issue:
Does the mere anticipation of a federal defense create federal question jurisdiction?
Holding:
No. The Court held that a federal question must arise from the plaintiff’s well-pleaded complaint, not from a defense. Since the Mottleys' claim was based on contract law (state law) and federal law was only a potential defense, federal jurisdiction was lacking.
Significance:
This case established the "Well-Pleaded Complaint Rule," restricting federal question jurisdiction to claims that arise directly under federal law.
b) Smith v. Kansas City Title & Trust Co., 255 U.S. 180 (1921)
Facts:
Plaintiffs alleged that a city’s bond issue violated the federal Constitution because it conflicted with the Fourteenth Amendment.
Issue:
Does a case that involves a federal constitutional question as part of the plaintiff’s claim confer federal question jurisdiction?
Holding:
Yes. The Court found that because the plaintiff’s claim was founded on the federal Constitution, the federal courts had jurisdiction.
Significance:
This case confirmed that federal courts can hear cases where the plaintiff’s claim necessarily depends on a federal constitutional issue.
c) Merrell Dow Pharmaceuticals Inc. v. Thompson, 478 U.S. 804 (1986)
Facts:
Plaintiffs sued a drug manufacturer for a defective drug that allegedly caused birth defects. The claim was under state law but referenced violations of federal drug regulations.
Issue:
Does the violation of a federal statute automatically create federal question jurisdiction?
Holding:
No. The Court held that a state-law claim that incorporates a federal standard does not automatically confer federal jurisdiction if the federal statute does not provide a private right of action.
Significance:
This case clarified that federal question jurisdiction is not conferred simply by mentioning a federal law, especially if that law does not create a private cause of action.
d) Gunn v. Minton, 568 U.S. 251 (2013)
Facts:
A legal malpractice claim was brought under Texas state law, but the malpractice claim depended on a patent issue, which is a federal subject.
Issue:
Does federal question jurisdiction exist if a state law claim necessarily raises a substantial federal issue?
Holding:
Yes. The Court held that federal question jurisdiction applies where a state law claim necessarily raises a federal issue that is (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution in federal court without disrupting the federal-state balance.
Significance:
This case refined the doctrine by allowing federal jurisdiction over certain state law claims that raise important federal issues, emphasizing a “substantial federal issue” test.
e) Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, 545 U.S. 308 (2005)
Facts:
Grable sued Darue in federal court for a state law quiet title action involving property seized by the IRS, which required interpretation of a federal tax statute.
Issue:
Can a state law claim that involves a federal issue confer federal question jurisdiction?
Holding:
Yes, under certain conditions. The Court held federal jurisdiction existed because the federal issue was (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution in federal court without disturbing the balance of federal and state judicial responsibilities.
Significance:
Grable articulated a “federal ingredient” test to determine federal question jurisdiction in state law claims involving federal issues.
4. Summary of Federal Question Jurisdiction Principles
| Case | Principle | Importance |
|---|---|---|
| Louisville & Nashville Railroad v. Mottley | Well-pleaded complaint rule: federal question must appear on complaint’s face | Limits federal jurisdiction to claims based on federal law |
| Smith v. Kansas City Title & Trust | Federal courts have jurisdiction if claim arises under federal Constitution | Confirms constitutional claims invoke federal jurisdiction |
| Merrell Dow Pharmaceuticals | Merely referencing federal law does not confer jurisdiction | Protects state courts from federal overreach |
| Grable & Sons Metal Products | State claims with a substantial federal issue may qualify | Expands jurisdiction when federal issue is important |
| Gunn v. Minton | Federal jurisdiction when state claim necessarily raises a substantial federal question | Refines test for substantial federal question |
5. Practical Implications
Federal courts cannot hear cases just because a federal law might be involved in the defense.
If a plaintiff’s claim is based on federal law, federal courts have jurisdiction.
Some state law claims that raise important federal issues may be heard in federal court.
Federal question jurisdiction ensures uniformity and proper enforcement of federal laws.
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