Federal Courts Cases Outline
The topic of federal courts encompasses the ways in which federal courts may exercise judicial power, the parameters of which are generally decided by Congress. The Supreme Court’s original and appellate jurisdiction are derived from Article III, Section 2 of the Constitution. The jurisdiction of the federal courts includes constitutional law, statutory law, and common law. Federal courts may also hear state civil cases brought under diversity jurisdiction. Below is an outline of key cases discussing the role of federal courts with links to the full text of virtually every case, provided free by Justia.
Judicial Review
The Supreme Court’s power of judicial review allows it to declare a legislative or executive act unconstitutional.
Marbury v. Madison 一 The Supreme Court has the power to declare legislation unconstitutional. Congress does not have the power to pass laws that override the Constitution and cannot expand the scope of the Supreme Court’s original jurisdiction.
Section 1983 Actions
A federal remedy is available under 42 U.S.C. Section 1983 for individuals deprived of their rights under the Constitution or federal law by someone else acting under color of state or local law. Section 1983 actions commonly involve allegations of police misconduct or prisoner mistreatment, among other subjects.
Monroe v. Pape 一 A party does not need to seek a state remedy before seeking a federal remedy under 42 U.S.C. 1983, since these remedies are supplemental.
Monell v. Department of Social Services 一 Local governments are not immune from suit under 42 U.S.C. 1983. Governing bodies (and officials sued in their official capacity) may be liable under Section 1983 when their policy or custom inflicted the injury.
Pembaur v. City of Cincinnati 一 A policy used to establish Section 1983 liability may be a single decision made by policymakers, rather than a repeated action.
Webb v. Sloan 一 If the subject action is taken by a final policymaker, a single action may suffice for Section 1983 liability.
City of Canton, Ohio v. Harris 一 Inadequate training may be sufficient for Section 1983 liability when the failure to train amounts to deliberate indifference to the constitutional rights of a person with whom the officer may come in contact, and the inadequate training is sufficiently related to the injury.
Baron v. Suffolk County Sheriff’s Dep’t 一 A custom is attributable to a municipality when it is so well settled and widespread that policymakers had actual or constructive notice of it but did nothing about it. Section 1983 liability may arise when a custom is fairly attributable to the municipality, and it was the cause of and moving force behind the deprivation.
Official Immunity
Officials may raise an absolute or qualified immunity defense to a Section 1983 action. Absolute immunity is limited in scope, but an official may have qualified immunity in instances in which they do not have absolute immunity.
Forrester v. White 一 State court judges are not entitled to absolute immunity from Section 1983 actions for demoting and dismissing court employees because such decisions are administrative, rather than judicial.
Wood v. Strickland 一 Qualified immunity is not available when officials knew or should have known that their official actions violated an individual’s constitutional rights, or when they acted with malicious intent. (The subjective standard concerning an official’s motive was abandoned in Harlow v. Fitzgerald.)
Harlow v. Fitzgerald 一 Qualified immunity applies to presidential aides and other government officials performing discretionary functions, and it can be penetrated only when they have violated clearly established statutory or constitutional rights.
Hope v. Pelzer 一 Officials may be on notice that actions would violate clearly established statutory or constitutional rights even if a court has never addressed a factually similar case, so long as the state of the law gave officials fair warning.
Federal Common Law
Federal courts sometimes have the power to develop federal common law when an issue arises that is not addressed by a statute or the Constitution.
Swift v. Tyson 一 When a federal court sitting in diversity jurisdiction rules on an issue that has not been addressed by the state legislature, it may develop a federal common law that is different from the state common law. (This decision was overruled by Erie Railroad Co. v. Tompkins.)
Black & White Taxicab & Transfer Co. v. Brown & Yellow Taxicab & Transfer Co. 一 Federal courts must apply relevant state statutes and constitutions in diversity cases, but they are not bound by state common law.
Erie Railroad Co. v. Tompkins 一 Federal courts sitting in diversity jurisdiction generally should apply state substantive law and federal procedural law.
D’Oench, Duhme & Co., Inc. v. FDIC 一 Federal common law may be appropriate in non-diversity cases when there is no applicable federal statute, and there is a sufficiently strong federal interest in creating federal common law.
U.S. v. Hudson 一 Federal courts cannot exercise common-law jurisdiction over criminal cases. Congress must create a federal crime and confer jurisdiction over the offense to federal courts before they may exercise jurisdiction over such matters.
Implied Private Rights of Action
Under limited circumstances, the Supreme Court has identified implied private rights of action when there is no remedy explicitly provided by the law.
Alexander v. Sandoval 一 There is no private right of action to enforce disparate-impact regulations promulgated under Title VI of the Civil Rights Act of 1964.
Bivens v. Six Unknown Fed. Narcotics Agents 一 While there is no explicit right to file a civil lawsuit against federal government officials who have violated the Fourth Amendment, this right can be inferred because a constitutional protection would not be meaningful if there were no way to seek a remedy for a violation of it.
Minneci v. Pollard 一 There is no implied Bivens remedy when state law authorizes adequate alternative damages actions for private prison employees’ Eighth Amendment violations which both deter violations and compensate victims.
Ziglar v. Abbasi 一 Implied Bivens rights of action are very rare and will only be found when the claim is meaningfully different from previous Bivens cases, and special factors weigh in favor of the courts (rather than Congress) determining whether to allow a damages action.
Reich v. Collins 一 An injured taxpayer is entitled to a remedy if their due process rights were violated when the state reconfigured its remedial scheme midcourse (a state could not hold out a clear and certain post-deprivation remedy through its tax refund statute and then declare after taxpayers had paid the disputed taxes that the remedy did not exist).
Rights and Obligations of the United States
When the rights and obligations of the United States are implicated, federal courts must balance federal interests with other important concerns.
Clearfield Trust Co. v. U.S. 一 A federal court can make a common-law rule regarding federal negotiable instruments, since they are controlled by federal law, and uniformity is especially important when determining the rights and duties of the United States.
U.S. v. Kimbell Foods, Inc. 一 When uniformity is less important than other concerns, as in the case of commercial transactions, federal decisions may incorporate state law to determine the rights of the United States.
U.S. v. Little Lake Misere Land Co., Inc. 一 Federal courts need not borrow state law when the state law specifically deviates from or is hostile to federal government interests.
Boyle v. United Technologies Corp. 一 Federal law may displace state law in areas of unique federal interest when there is a significant conflict between the operative state law and an identifiable federal policy or interest.
O’Melveny & Myers v. FDIC 一 In a suit by the FDIC as receiver of a California savings and loan, the California rule of decision, rather than a federal common-law rule, governed the tort liability of attorneys who provided services to the bank.
Federal Question Jurisdiction
Federal courts have subject matter jurisdiction over a case when there is a federal question. Generally, there is a federal question when the case arises under federal law, as described in 28 U.S.C. Section 1331. Federal question jurisdiction requires that the plaintiff’s complaint state the federal question on its face.
American Well Works Co. v. Layne & Bowler Co. 一 A federal court cannot hear an action based on damages caused to a business by a threat to sue for patent infringement, since this is not an action under federal patent laws, but under state law.
Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg. 一 Jurisdiction over federal issues in state claims depends on whether the state claim necessarily states a federal issue that is actually disputed and substantial, and a federal forum may entertain the issue without disturbing the congressionally approved balance between federal and state courts.
Gunn v. Minton 一 While the resolution of a patent question in a malpractice suit may be necessary and actually in dispute, it is not significant enough to raise a federal question sufficient for federal jurisdiction. Whether a federal issue is substantial is measured by the importance of the issue to the federal system as a whole, rather than the importance of the issue to the parties in the case.
Louisville & Nashville R. Co. v. Mottley 一 To determine whether federal question jurisdiction is appropriate, a court should consider only the complaint, rather than any anticipated defenses.
Holmes Group, Inc. v. Vornado Air Circulation Systems, Inc. 一 Federal question jurisdiction does not arise when the federal question is only implicated in a counterclaim.
Beneficial Nat’l Bank v. Anderson 一 When a federal statute completely preempts a state cause of action, providing an exclusive cause of action, that claim may be removed to federal court without meeting the requirements of the well-pleaded complaint rule.
Skelly Oil Co. v. Phillips Petroleum Co. 一 The Declaratory Judgment Act is procedural only and did not expand federal court jurisdiction when it expanded available remedies.
Franchise Tax Bd. of Cal. v. Construction Laborers Vacation Trust 一 A case is not removable to federal court if a federal question only arises by defense. Furthermore, a case is not removable to federal court when a federal question arises in a complaint for state declaratory relief when the federal question would be barred by Skelly Oil Co. if the plaintiff had sought a federal declaratory judgment.
Diversity Jurisdiction
In addition to federal question jurisdiction, the other way in which a federal district court may have original jurisdiction over a case is diversity jurisdiction. Diversity jurisdiction generally arises when the amount in controversy exceeds $75,000, and no plaintiff is a citizen of the same state as any defendant, as described in 28 U.S.C. Section 1332.
Gregg v. Louisiana Power & Light Co. 一 For the purposes of diversity jurisdiction, a person is usually considered domiciled in the state of their birth unless a new domicile is acquired.
Hertz Corp. v. Friend 一 For the purposes of diversity jurisdiction, a corporation’s principal place of business can be defined as its “nerve center,” where its leading officers direct, control, and coordinate its activities.
United Steelworkers of America v. R.H. Bouligny, Inc. 一 In the case of an unincorporated labor union, citizenship is determined by the citizenship of each of its members.
Kramer v. Caribbean Mills, Inc. 一 When a party brings a claim in a manner that is improperly or collusively designed to create diversity jurisdiction, a federal court should dismiss it for that reason.
Owen Equipment & Erection Co. v. Kroger 一 Federal jurisdiction over a state law claim is not automatically established whenever the state claim arises from the same nucleus of operative fact as any federal claims. A court must also consider the statute that provides jurisdiction over the federal claim and the context in which the state claim arose.
Supplemental Jurisdiction
Generally, federal district courts have supplemental jurisdiction over all claims that are so related to claims in the action within their original jurisdiction that they form part of the same case or controversy, as expressed in 28 U.S.C. Section 1367.
United Mine Workers of America v. Gibbs 一 A federal court has discretion to review a state claim when there is a sufficient federal claim in the same action, and the relationship between the federal claim and the state claim suggests that the entire action comprises one case (a “common nucleus of operative fact”).
Exxon Mobil Corp. v. Allapattah Services, Inc. 一 So long as one plaintiff meets the amount in controversy requirement, a federal court may exercise supplemental jurisdiction over sufficiently related claims that do not meet the amount in controversy requirement.
Justiciability
Justiciability is simply whether a case is suitable for court. Justiciability concerns issues of standing, ripeness, mootness, and fitness. Federal courts cannot issue advisory opinions, render judgments that are not final, or resolve political questions.
U.S. v. Johnson 一 Collusive suits are nonjusticiable because there are no adverse parties.
MedImmune, Inc. v. Genentech, Inc. 一 Declaratory judgments are permissible if there is a concrete, immediate, and definite case or controversy that may be completely resolved by judicial determination.
Plaut v. Spendthrift Farm, Inc. 一 Congress cannot order a federal court to reopen a final judgment by enacting retroactive legislation.
Zivotofsky v. Clinton 一 A question as to whether an individual may vindicate their statutory right when the subject statute allows a U.S. citizen born in Jerusalem to record their place of birth as Israel is not a political question.
Baker v. Carr 一 The political question doctrine arises when (1) there is a textually demonstrable constitutional commitment of the issue to a coordinate political department, (2) there is a lack of judicially discoverable and manageable standards for resolving the question in court, (3) it is impossible to decide without an initial policy determination of a kind clearly for non-judicial discretion, (4) it is impossible for the court to undertake independent resolution without expressing a lack of respect for coordinate branches of government, (5) there is an unusual need for unquestioning adherence to a political decision already made, or (6) there is potential for embarrassment from multifarious pronouncements by various departments on one question. Fourteenth Amendment claims concerning redistricting are not political questions.
Standing and Injury Requirements
Standing generally requires that a plaintiff suffered actual harm caused by the challenged act and that their harm is redressable. Generalized grievances and speculative redressability are two ways in which a court may find that a party does not have standing.
Ex parte Levitt 一 Standing requires that an individual show that they have sustained or are in immediate danger of sustaining a direct injury as a result of the contested action. A general interest common to all members of the public is insufficient.
Warth v. Seldin 一 In addition to the constitutional requirements of standing, there may be prudential limitations on federal jurisdiction in resolving disputes involving generalized grievances or third parties’ legal rights or interests.
Northeastern Fla. Chapter of the Associated Gen. Contractors of America v. Jacksonville 一 An injury in fact may be a denial of equal treatment and does not necessitate that the individual would have obtained the benefit but for the barrier. Furthermore, voluntary cessation of a challenged practice does not render a case moot.
Clapper v. Amnesty Int’l USA 一 Not only must an injury be certainly impending rather than speculative, but also it must be fairly traceable to a certain cause.
Simon v. Eastern Kentucky Welfare Rights Org. 一 A plaintiff must establish standing by showing that an injury to them, traceable to a challenged act of the defendant, is likely to be redressed by a favorable decision.
Association of Data Processing Svc. Orgs. v. Camp 一 Standing is only established if the interest sought to be protected is within the “zone of interest” to be protected or regulated by the statute or constitutional guarantee in question.
Lexmark Int’l, Inc. v. Static Control Components, Inc. 一 The zone of interest test is not a prudential standing test.
Lujan v. Defenders of Wildlife 一 When Congress authorizes private parties to bring claims based on procedural wrongs, these plaintiffs still must show a concrete and imminent injury to establish standing.
Kowalski v. Tesmer 一 Third-party standing is appropriate when the party has a close relationship with the person possessing the right, and the person possessing the right is hindered in protecting their own interests. An existing attorney-client relationship can be a “close” relationship for third-party standing, but not a hypothetical future attorney-client relationship.
Federal Election Comm’n v. Akins 一 Standing may exist even when a plaintiff’s injury is widely shared by other citizens, so long as it is sufficiently concrete.
Hollingsworth v. Perry 一 A citizen has no standing to appeal an adverse federal ruling on behalf of a state when state officials decline to do so and the citizen’s complaint is no more than a generalized grievance.
Spokeo, Inc. v. Robins 一 A mere procedural violation is not enough to constitute a concrete and particularized injury that confers standing.
Linda R.S. v. Richard D. 一 There is no redressability when only a speculative connection exists between the desired result and the remedy sought.
Friends of the Earth, Inc. v. LaidLaw Environmental Services, Inc. 一 Civil penalties may be an acceptable form of redress when they effectively abate and prevent the recurrence of conduct that injured or threatened an injury to the plaintiff. Furthermore, voluntary cessation of a challenged practice without clear evidence that the practice could not reasonably be expected to recur does not render a case moot.
Steel Co. v. Citizens for a Better Environment 一 Civil penalties are not an acceptable form of redress for past violations, but they may be for future violations.
Taxpayer Standing
A federal taxpayer generally does not have standing to challenge a federal expenditure merely because they are a taxpayer. However, Flast v. Cohen carved out an exception in 1968.
Commonwealth of Massachusetts v. Mellon 一 An individual does not have standing to challenge a federal expenditure simply because they are a federal taxpayer.
Flast v. Cohen 一 Although taxpayers generally lack standing to sue, they do have standing when there is a logical link between their taxpayer status and the challenged legislative enactment, and the enactment exceeds specific constitutional limitations on the exercise of the taxing and spending power.
U.S. v. Richardson 一 There is no standing for a taxpayer bringing a generalized grievance against regulations of an agency’s accounting and reporting procedures.
Valley Forge Christian College v. Americans United 一 The Flast test is not satisfied when the challenged act is a decision made by a government agency and is not an exercise of Congress’ authority under the Taxing and Spending Clause.
Hein v. Freedom From Religion Foundation, Inc. 一 The Flast test is not satisfied when the challenged act is an executive branch expenditure funded by general appropriations.
Ripeness and Mootness
A federal court may decline to decide a case when there is no dispute left for resolution (it is moot) or it is too early (it is not ripe). A case might not be considered moot when the parties will in fact be affected by the ruling going forward, when there is no evidence that actions that have been voluntarily ceased will not be repeated, when the same injury is likely to occur again to the same person, or when other members of a class continue to have live claims.
National Park Hospitality Ass’n. v. Dep’t of the Interior 一 Whether a case is ripe depends on its present fitness for adjudication and the hardship to the parties of withholding consideration.
City of Los Angeles v. Lyons 一 Past conduct alone is insufficient to establish standing for injunctive relief.
Chafin v. Chafin 一 A case is moot when the issues are no longer “live” or when the parties lack a legally cognizable interest in the outcome.
U.S. Parole Comm’n v. Geraghty 一 Mootness does not arise in a class action when the named plaintiff’s substantive claim ends, even if the class was not certified.
The Eleventh Amendment and State Immunity
Under the Eleventh Amendment, states may not be sued in federal court by citizens. The Eleventh Amendment was proposed and ratified in direct response to the Supreme Court’s 1793 ruling in Chisholm v. Georgia, which allowed citizens to sue state governments in federal court.
Chisholm v. Georgia 一 Later nullified by the Eleventh Amendment, this decision allowed citizens of states to sue state governments in court because sovereign immunity was not found to apply.
Hans v. Louisiana 一 Under the Eleventh Amendment, federal courts cannot have jurisdiction over actions brought against a state by its own citizens.
Ex parte Young 一 If government officials attempt to enforce an unconstitutional law, sovereign immunity does not prevent people whom the law harms from suing those officials in their individual capacity for injunctive relief. This is because they are not acting on behalf of the state in this situation.
Armstrong v. Exceptional Child Ctr., Inc. 一 No implied private right of action can be inferred from the Supremacy Clause, since it does not create any federal rights, and the equitable power of federal courts to enjoin executive actions may be expressly and implicitly constrained by Congress.
Edelman v. Jordan 一 Federal courts cannot order states to pay back funds that were unconstitutionally withheld.
Ford Motor Co. v. Dep’t of Treasury 一 A state may invoke sovereign immunity in a suit to recover money from it even when individual officials are nominal defendants.
Scheuer v. Rhodes 一 State immunity does not bar suits for damages against state officials in their individual capacity in some circumstances.
Congressional Abrogation of State Immunity
Congress has some power to strip states of their sovereign immunity. For example, Congress may abrogate state sovereign immunity under Section 5 of the Fourteenth Amendment.
Fitzpatrick v. Bitzer 一 Congress can abrogate state sovereign immunity when it acts in connection with its enforcement power under Section 5 of the Fourteenth Amendment.
Seminole Tribe of Fla. v. Florida 一 Congress cannot strip states of their sovereign immunity without their consent.
Alden v. Maine 一 Congress cannot use its Article I powers to force states to surrender sovereign immunity from federal claims in their courts.
Central Va. Community College v. Katz 一 States cannot raise the defense of sovereign immunity in bankruptcy proceedings because the Bankruptcy Clause abrogates sovereign immunity.
Abstention
Federal courts may restrict their own power through abstention. Federal courts often abstain if a case involves a conflict with a state court’s power.
Railroad Comm’n of Texas v. Pullman Co. 一 If a state court can easily resolve a certain issue based on state law, a federal court may abstain from hearing the case.
Burford v. Sun Oil Co. 一 Federal courts should abstain in favor of state courts when the exercise of federal judicial power would be prejudicial to the public interest, including the independence of state governments.
Louisiana Power & Light Co. v. Thibodaux 一 Abstention is appropriate when there is unclear state law and a matter of great importance to a state that is “intimately involved with sovereign prerogative.”
Colorado River Water Conserv. Dist. v. U.S. 一 The interests of effective judicial administration may lead a federal court to abstain in a case when a concurrent state proceeding has started to unfold. A federal court may consider the inconvenience of the federal forum, the desirability of avoiding piecemeal litigation, and the order in which jurisdiction was obtained by the concurrent forums.
Wilton v. Seven Falls Co. 一 A federal court has a level of discretion in determining whether to stay a declaratory judgment action during parallel state court proceedings.
Ankenbrandt v. Richards 一 The domestic relations exception divests the federal courts only of the power to issue divorce, alimony, and child custody decrees.
Marshall v. Marshall 一 A federal court may exercise jurisdiction over some claims arising in the context of probate litigation so long as the federal court does not interfere with state court probate proceedings.
The Anti-Injunction Act
Under 28 U.S.C. Section 2283, a federal court may not grant an injunction to stay proceedings in a state court unless one of three exceptions applies: the injunction is expressly authorized by Congress, it is necessary to aid the jurisdiction of the federal court, or it is necessary to protect or effectuate its judgments.
Atlantic Coast L. R. Co. v. Brotherhood of Locomotive Engineers 一 Unless an injunction is authorized by Congress, necessary to further the court’s jurisdiction, or needed to protect or enforce the court’s judgment, a federal court cannot enjoin a state court proceeding under the Anti-Injunction Statute.
Mitchum v. Foster 一 A federal court can enjoin proceedings that are pending in a state court when 42 U.S.C. 1983 is involved, since this law falls within the expressly authorized exception of the Anti-Injunction Statute.
The Younger Doctrine
The Younger doctrine, established in the 1971 case of Younger v. Harris, holds that federal courts should not intervene in state proceedings unless this is necessary to prevent great and irreparable harm.
Younger v. Harris 一 Only if the defendant will face irreparable harm should a federal court enjoin pending state criminal prosecutions alleged to violate civil rights.
Samuels v. Mackell 一 The same principles governing whether federal injunctions of state criminal proceedings are appropriate apply to federal declaratory judgments in connection with state criminal proceedings.
Steffel v. Thompson 一 A federal court has the authority to hear a case challenging the constitutionality of a state criminal law and asking for declaratory relief when prosecution is merely threatened and not pending.
Doran v. Salem Inn, Inc. 一 The question of whether a federal court may grant preliminary injunctive relief when an individual has not yet broken the law depends on whether leaving the individual to defend against a state prosecution would subject them to a risk of serious and irreparable harm.
Huffman v. Pursue, Ltd. 一 A federal court may not interfere with state court proceedings when a litigant has not exhausted their state appeal remedies, and Younger standards are not met. Younger applies equally to certain civil proceedings akin to criminal prosecution.
Ohio Civil Rights Comm’n v. Dayton Christian Pub. Schools, Inc. 一 Federal courts may not interfere with state administrative proceedings unless Younger standards are met.
Pennzoil Co. v. Texaco, Inc. 一 Federal courts should abstain under the principles of Younger when a state court litigant had the opportunity to present their constitutional claims in state court, and the state’s interest in performing its judicial function is implicated.
Gibson v. Berryhill 一 Federal courts are not required to abstain from interfering with state administrative proceedings when those proceedings are biased.
Spirit Communications, Inc. v. Jacobs 一 The Younger doctrine is limited to state criminal cases, certain civil proceedings akin to criminal prosecution, and other civil proceedings that implicate a state’s interest in performing its judicial functions.
Supreme Court Review of State Court Judgments
Under 28 U.S.C. Section 1257, the Supreme Court has the ability to review certain final judgments and decrees of each state’s highest court by writ of certiorari.
Martin v. Hunter’s Lessee 一 The U.S. Supreme Court holds the power to review decisions by state courts that interpret federal law or the Constitution so that the law applies consistently across the states.
Fairfax’s Devisee v. Hunter’s Lessee 一 The Supreme Court may review a state court decision when federal issues are implicated.
Murdock v. Memphis 一 The Judiciary Act of 1867 does not give the Supreme Court jurisdiction to review state law questions in a case removed from a state court to the Supreme Court for review.
Fox Film Corp. v. Muller 一 The Supreme Court cannot review a state court decision that rests on an adequate and independent state law ground, even if a federal question may have been implicated.
Indiana ex rel. Anderson v. Brand 一 Federal courts may review state court decisions that implicate federal rights when a decision adverse to a federal right does not rest on independent state law grounds.
State Tax Comm’n v. Van Cott 一 A state court decision based on an interpretation of federal law does not rest on independent state law grounds for the purposes of federal court review.
Michigan v. Long 一 State court decisions that appear to rest largely on federal grounds without an independent and adequate state law ground are subject to federal review, but not if the state court opinion states that the case was resolved on separate state grounds.
Coleman v. Thompson 一 An adequate and independent state procedural default may prohibit federal review of a state court’s denial of a state prisoner’s federal constitutional claim unless the prisoner can demonstrate cause for the default and actual prejudice due to the violation of federal law, or show that a failure to review would result in a fundamental miscarriage of justice.
James v. Kentucky 一 A state criminal court decision may be subject to federal review if it is not clear that the decision rested on adequate and independent state law grounds when the state procedural rule cited is not so firmly established and regularly followed that it could bar consideration of federal constitutional rights.
Lee v. Kemna 一 Failing to comply with a firmly established and regularly followed state rule usually bars federal review. However, an exception applies when the application of the rule renders the state ground inadequate because the rule’s requirements were substantially met, and no state interest would be hindered by federal review.
Beard v. Kindler 一 The mere fact that a state procedural rule permits discretion does not render a state decision subject to federal review.
Cox Broadcasting Corp. v. Cohn 一 A decision of a state supreme court on a federal issue may be considered a final judgment for the purpose of an immediate appeal to the U.S. Supreme Court, even if the lower state courts have not completely concluded proceedings.
Preclusion and the Rooker-Feldman Doctrine
Federal courts aside from the Supreme Court are generally prohibited from reviewing state court decisions.
Allen v. McCurry 一 Issue preclusion applies when an issue raised in a Section 1983 action has already been decided by a state court after a full and fair opportunity to litigate that issue.
Exxon Mobil Corp. v. Saudi Basic Industries Corp. 一 The scope of the Rooker-Feldman doctrine is limited to cases brought by parties that lose at the state court level before federal court proceedings have begun and that allege harm by the judgments at that level, which they are seeking to reverse at the federal level. The Rooker-Feldman doctrine is not implicated when there is parallel state and federal litigation, and the state court issues a judgment.
Lance v. Dennis 一 A litigant in privity with a party who lost in state court may be subject to issues of preclusion, but not automatic dismissal under the Rooker-Feldman doctrine.
Congress’ Authority Over Federal Jurisdiction
Congress has the power to control the jurisdiction of the lower federal courts and limited power to control the jurisdiction of the Supreme Court.
Tennessee v. Davis 一 Congress can mandate by law that some types of criminal prosecutions should be removed from state to federal court.
Osborn v. Bank of the United States 一 When Congress authorizes a party to sue and be sued, this provides federal subject matter jurisdiction over cases involving that party. The mere presence of state law elements does not hinder federal jurisdiction.
Sheldon v. Sill 一 Congress may restrict the jurisdiction of lower federal courts by statute, notwithstanding the separation of powers.
Battaglia v. General Motors Corp. 一 While Congress may control the jurisdiction of courts other than the Supreme Court, it must still comply with the Fifth Amendment so that it does not deprive any person of life, liberty, or property without due process of law or take property without just compensation.
Boumediene v. Bush 一 Congress must provide an adequate substitute if it suspends habeas corpus.
Ex parte McCardle 一 The Constitution gives the Supreme Court its appellate jurisdiction, but Congress also has the power to make exceptions to it.
Ex parte Yerger 一 The Supreme Court has the authority to grant writs of habeas corpus.
Northern Pipeline Constr. Co. v. Marathon Pipe Line Co. 一 It is unconstitutional for Congress to confer Article III power on Article I bankruptcy judges, who lack the independence and protection given to Article III judges. There are limits to the powers that Congress may grant to non-Article III tribunals.
CFTC v. Schor 一 The Commodity Exchange Act permits the CFTC to create regulations governing the adjudication process of certain common-law counterclaims. The CFTC may adjudicate common-law counterclaims in reparations proceedings so long as they arise from the same transaction, and the parties have waived their right to proceed in an Article III court.
Stern v. Marshall 一 A bankruptcy court cannot constitutionally enter a final judgment on a compulsory state law counterclaim when that counterclaim is not resolved in the process of ruling on a creditor’s proof of claim.
This outline has been compiled by the Justia team for solely educational purposes and should not be treated as an independent source of legal authority or a summary of the current state of the law. Students should use this outline as a supplement rather than a substitute for course-specific outlines.
