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Capron v. Van Noorden Case Brief

Summary of Capron v. Van Noorden
Supreme Court of the United States, 1804.

6 U.S. (2 Cranch) 126, 2 L.Ed. 229.

Facts: Capron (P) sues Van Noorden (D) for “trespass on the case” (negligence).  P lost case and then appealed on the grounds that the case should not have been allowed to go to federal court since there wasn’t a federal issue or diversity of citizenship.

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

Rule:  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.

Application:  Because P’s case lacked the proper subject matter jurisdiction for Federal Court, the case was thrown out.

Conclusion:  The Supreme Court overturned the verdict in favor of D.  This doesn’t mean that D won, simply that the trial never occurred.



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