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Strawbridge v. Curtiss

Supreme Court of the United States - 7 U.S. 267 (1806)

Main Takeaway

Federal diversity jurisdiction requires complete diversity where all parties with joint interests must individually satisfy federal court jurisdictional requirements. When parties share unified legal interests, each party must independently meet citizenship requirements rather than allowing diverse parties to carry non-diverse co-parties into federal court.

Issues

Can federal courts exercise jurisdiction over a case where some parties are citizens of different states but others are not competent to sue in federal court?

Facts

This case involved a jurisdictional challenge in federal court. The parties had joint interests in the matter, but not all parties met the requirements for federal jurisdiction under the diversity statute. Some parties were competent to sue or be sued in federal courts while others were not. The case raised the question of whether complete diversity of citizenship was required for federal jurisdiction when parties shared joint interests.

Procedural History

The case was brought in federal court based on diversity jurisdiction. The court considered whether it had proper jurisdiction over the matter given the citizenship status of the parties involved. The lower court's decree was ultimately affirmed by the Supreme Court.

Holding and Rationale

(Marshall, J.)

No. Federal courts cannot exercise jurisdiction over cases involving joint interests where some parties are not competent to sue in federal court. The Judiciary Act requires that where parties have joint interests, each person concerned in that interest must be competent to sue or liable to be sued in federal courts. The statutory language requiring diversity between citizens of different states means that each distinct interest should be represented by persons who are all entitled to sue or may be sued in federal courts. Complete diversity is therefore required for cases involving joint interests. The court specifically declined to address situations where several parties represent several distinct interests and some parties are competent while others are not competent to sue in federal court, leaving that question for future determination.

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