ARTICLE III v. STATUTORY JURISDICTION
Adapted from Glannon, Joseph W., Civil Procedure: Examples
and Explanations 57, Figure 4-1 (2d Ed. Little, Brown 1992).
Explanation. Generally, the green area represents the
maximum extent of Article III, § 2, Clause 1 jurisdiction
for the Federal Courts.
- Federal Question. In Loisville & Nashville RR
v. Mottley, we saw how the Supreme Court interpreted the predecessor
of Section 1331 more narrowly than Title III. Therefore, the
green area represents the full extent of Art. III, § 2,
Clause 1, Part [i] jurisdiction, and the blue represents the
narrower interpretation of the very similar language in Section
1331.
- Diversity. The green area also represents the maximum
extent of Diversity Jurisdiction allowed by the Constitution
of the United States, under the categories of Diversity of [American]
Citizenship and Alienage Jurisdiction. The blue area represents
what was actually granted in the enabling legislation, as interpreted
in Strawbridge v. Curtiss , 7 US (3 Cranch) 267 (1806).
Out of the blue area are Simple Diversity cases, i.e., cases
involving citizens of more than one U.S. state, which nonetheless
fail the Complete Diversity test created by Strawbridge,
as well as Complete Diversity cases that fail to meet the jurisdictional
amount requirement of section 1332.
- Diversity Illustration. The illustration I used in
class was a suit by a Citizen of Florida against two defendants,
one a citizen of Florida, the other a citizen of Georgia. This
is a "[Controversy] between Citizens of different States",
which would be within the language of Art. III, Sec. 2, Clause
[vii], BUT it is not a case of complete diversity, as required
by § 1332 as interpreted in Strawbridge.
This graphic should be read together with my annotated version
of Article III, Section 2, Clause 1:
US CONST. ART. III SECTION 2, CLAUSE 1
The judicial Power [of the United States] shall extend to
[i] all Cases, in Law and Equity, arising under this Constitution,
the Laws of the United States, and Treaties made, or which shall
be made, under their Authority; [ii]-to all Cases affecting Ambassadors,
other public Ministers or Consuls; [iii]-to all Cases of admiralty
and maritime Jurisdiction; [iv]-to Controversies to which the
United States shall be a Party; [v]-to Controversies between two
or more States; [vi]-[Controversies] between a State and Citizens
of Another State; [vii]-[Controversies] between Citizens of different
States; [viii]-[Controversies] between Citizens of the same State
claiming Lands under Grants of different States, and [ix] [Controversies]
between a State, or the Citizens thereof, and foreign States,
Citizens or Subjects.