The Law School Authority

Strawbridge v. Curtiss Case Brief

Summary of Strawbridge v. Curtiss
7 U.S. 267 (1806)

Facts: P, a resident of Massachusetts, brought action against D, a resident of Vermont, and other Ds, residents of Massachusetts. Action brought in Federal Court based on diversity of citizenship.

Procedure: Lower court dismissed for lack of subject matter jrx.

Issue: Does federal court have subject matter jurisdiction when one defendant is from different state but other defendants from the same state as P?

Holding: No

Rationale: You need complete diversity in order to have subject matter jrx. Even one D who is from the same state as the P, destroys diversity.

Note: Federal courts are courts of limited jurisdiction. Federal courts have subject matter jurisdiction over cases brought under federal laws (federal question jurisdiction) or under diversity of citizenship (complete diversity). For Diversity of Citizenship, see 28 U.S.C. 1332.

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