Subject Matter Jurisdiction
What is the Subject Matter Jurisdiction?
Subject matter jurisdiction is the court's authority to hear a particular type of case. Federal courts are courts of limited jurisdiction and require an independent basis such as federal question or diversity jurisdiction for every claim.
Definition
Subject matter jurisdiction refers to a court's competence to hear and decide a particular category of case. Unlike personal jurisdiction, which concerns power over the parties, subject matter jurisdiction concerns the court's authority over the type of dispute itself. Federal courts are courts of limited jurisdiction, meaning they can only hear cases falling within the judicial power granted by Article III of the Constitution and further authorized by Congress through jurisdictional statutes.
The two primary bases for federal subject matter jurisdiction are federal question jurisdiction under 28 U.S.C. section 1331 and diversity jurisdiction under 28 U.S.C. section 1332. Federal question jurisdiction exists when the plaintiff's well-pleaded complaint raises an issue of federal law. Diversity jurisdiction exists when the dispute is between citizens of different states and the amount in controversy exceeds $75,000. Additional bases include supplemental jurisdiction under section 1367 and removal jurisdiction under section 1441.
Subject matter jurisdiction cannot be waived, consented to, or conferred by agreement of the parties. A court has an independent obligation to examine its own jurisdiction at any stage of the proceedings, and a case must be dismissed if subject matter jurisdiction is found lacking, even on appeal. This distinguishes subject matter jurisdiction from personal jurisdiction and most other procedural requirements, which can be waived if not timely raised.
Key Elements
- 1The court must have constitutional and statutory authority to hear the type of case
- 2Federal courts require an independent basis for jurisdiction over each claim
- 3Subject matter jurisdiction cannot be waived or conferred by consent
- 4The court must dismiss the case if jurisdiction is found lacking at any stage
- 5The burden of establishing subject matter jurisdiction rests on the party invoking federal jurisdiction
Landmark Cases
Marbury v. Madison
5 U.S. (1 Cranch) 137 (1803)
Established the principle of judicial review and confirmed that federal courts are courts of limited jurisdiction that must have constitutional and statutory authority to act.
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (1994)
Reaffirmed that federal courts are courts of limited jurisdiction and the burden of establishing jurisdiction rests on the party asserting it.
Capron v. Van Noorden
6 U.S. (2 Cranch) 126 (1804)
Early case establishing that subject matter jurisdiction can be raised at any time, including by the party who originally invoked federal jurisdiction.
Arbaugh v. Y&H Corp.
546 U.S. 500 (2006)
Clarified the distinction between true jurisdictional requirements and non-jurisdictional claim-processing rules, establishing a bright-line test for jurisdictional characterization.
Exam Tips
- Always address subject matter jurisdiction before reaching the merits. If the court lacks subject matter jurisdiction, nothing else matters.
- Remember that unlike personal jurisdiction and venue, subject matter jurisdiction cannot be waived and can be raised at any point in the litigation.
- On an exam, systematically check federal question jurisdiction first, then diversity, then supplemental jurisdiction for any remaining claims.
Common Mistakes to Avoid
- Confusing subject matter jurisdiction with personal jurisdiction; they are independent requirements and both must be established.
- Assuming that subject matter jurisdiction can be waived if not raised in the initial pleadings, when in fact it can never be waived.
- Failing to independently assess subject matter jurisdiction for each claim in multi-claim litigation.
Memory Aid
SMJ = never waivable. Check it first, check it always.