Capron v. Van Noorden: Difference between revisions

Capron v. Van Noorden, 6 U.S. 126 (1804).

FACTS:

• Capron (P) sued Van Noorden (D) for trespass on the case (old form of negligence) in Fed Cir. Ct. of NC
• P alleged in complaint that D was a resident of NC, he did not allege himself was a resident of some other state or foreign country
• Case did not involve any issue of federal law, could have only been heard in fed court if there was a diversity jurisdiction
• P did not allege the necessary elements of diversity jurisdiction and circuit court should have dismissed the case  circuit court heard the case and P lost
  • P appealed to SCOTUS but not on grounds he should have won in trial court; argued that his own complaint was defective and should not have been allowed to go to trial

PROCEDURAL HISTORY:

• Writ of Error to US Circuit Court of NC for its judgment in action for damages for trespass on the case (negligence)
  • Circuit court should have dismissed, P lost, P appealed to SCOTUS

ISSUE: Will the federal courts throw out a case on appeal for lack of proper subject matter jurisdiction?

HOLDING: Yes.

ANALYSIS:

1. The federal courts have limited jurisdiction, which means they cannot hear just any case brought before them → Article 3 of the Constitution, §2; diversity of citizenship between citizens of different states
   1. Even if a case has carried on for a long, expensive period of time, the case should be thrown out if there is not proper jurisdiction
   2. Fed Courts cannot overstep the bounds of the Constitution and try a case if it should be left to the state courts → breach of the essential compromise at the heart of American government
      1. Infringement on State Sovereignty
   3. The case being thrown out worked in P’s favor. Normally cases can not be retried once decided, but now that the case seems to have never happened at all, P can file the correct complaint and have it retried if he so wishes
   4. Proper jurisdiction for a case must exist if the trial is to continue; it’s a case of Subject Matter Jurisdiction
   5. This case seems to violate Res Judicata

FINAL DEPOSITION: Judgment reversed. Its as if the trial never happened.

BLACK LETTER: In the Federal Courts, a case will be thrown out for lack of subject matter jurisdiction even if it has already made it to the appellate stage by the time the problem is discovered.

External Link:

• Capron v. Van Noorden at Justia.com