Capron v. Van Noorden
Capron v. Van Noorden, 6 U.S. 126 (1804).
- 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
- 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?
- 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
- 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
- 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
- Infringement on State Sovereignty
- 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
- Proper jurisdiction for a case must exist if the trial is to continue; it’s a case of Subject Matter Jurisdiction
- 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.