Module 1: Jurisdiction & Venue

Under 28 U.S.C. § 1331, federal district courts have jurisdiction over claims arising under the Constitution, federal law, or treaties. The well-pleaded complaint rule requires the federal issue to appear on the face of the plaintiff’s own complaint — an anticipated federal defense, even a certain one, doesn’t count.

Louisville & Nashville Railroad Co. v. Mottley, 211 U.S. 149 (1908), is the foundational case establishing the well-pleaded complaint rule itself. A couple had settled a personal injury claim against a railroad in exchange for the railroad’s promise of free lifetime train passes; years later, a new federal statute banned free passes, and the railroad stopped honoring them. The couple sued for breach of the settlement agreement, anticipating in their own complaint that the railroad would defend by arguing the new federal statute excused its performance — and arguing that this anticipated federal defense itself created federal question jurisdiction. The Supreme Court disagreed and dismissed the case for lack of jurisdiction, holding that federal question jurisdiction depends entirely on what the plaintiff’s own claim actually is, not on any defense the defendant might later raise — even a defense that everyone already knows is coming and is certain to be the real, contested issue in the case. The case remains the reason a purely state-law claim never becomes a federal one just because the defendant plans to invoke federal law in response.

Example. A plaintiff sues under a federal civil rights statute — the complaint itself states a federal claim, so federal question jurisdiction is straightforward. Now compare a plaintiff suing for ordinary breach of contract, where the defendant plans to argue a federal statute preempts the claim. That anticipated federal defense doesn’t create federal question jurisdiction — the well-pleaded complaint itself states only a state-law claim.

Under 28 U.S.C. § 1332, federal courts have jurisdiction over cases between citizens of different states where the amount in controversy exceeds $75,000, exclusive of interest and costs. This requires complete diversity — no plaintiff may share citizenship with any defendant. A corporation is a citizen of both its state of incorporation and the state of its principal place of business.

The complete diversity requirement — stricter than the Constitution itself actually demands — comes from Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267 (1806). Chief Justice Marshall, writing for the Supreme Court in a case involving multiple plaintiffs and multiple defendants, held that diversity jurisdiction under the relevant statute requires every plaintiff to be diverse from every defendant — not merely minimal diversity between at least some of the parties. Congress could constitutionally authorize the broader “minimal diversity” version (and occasionally has, in narrow statutes like the Class Action Fairness Act), but Strawbridge fixed the default, general-purpose diversity statute at the stricter complete-diversity reading, and that interpretation has remained essentially unchanged for well over two centuries. It’s the direct reason a single shared citizenship anywhere in a multi-party case can defeat diversity jurisdiction entirely, no matter how clearly diverse every other party pairing might be.

Example. A California plaintiff sues a Texas corporation (incorporated in Delaware, headquartered in Texas) for $200,000. No overlap in citizenship, and the amount exceeds $75,000 — diversity jurisdiction exists. Now compare: a second plaintiff from Texas joins the suit. That destroys complete diversity entirely, since a Texas plaintiff now shares citizenship with the Texas-headquartered defendant.

Under 28 U.S.C. § 1367, a federal court with jurisdiction over one claim may also hear related claims — even purely state-law ones with no independent jurisdictional basis — that share a common nucleus of operative fact with the properly filed claim, letting the whole dispute be resolved in one case.

The “common nucleus of operative fact” language itself comes straight from United Mine Workers v. Gibbs, 383 U.S. 715 (1966), the case that first articulated the modern test (there, for what was then called “pendent jurisdiction,” the doctrine’s judicial predecessor before Congress codified it as supplemental jurisdiction in § 1367). A union official brought both a federal labor-law claim and a related state-law tort claim against the same union arising from the same underlying labor dispute; the Supreme Court held that a federal court with a substantial federal claim may exercise discretion to also hear the state-law claim, so long as both claims derive from a common nucleus of operative fact such that the plaintiff would ordinarily be expected to try them together in one proceeding. The Court was careful to frame this as a discretionary power, not an entitlement — a district court can still decline supplemental jurisdiction (and § 1367 later codified specific grounds for doing so) where the state-law claims substantially predominate or the federal claims drop out of the case early.

Example. A plaintiff brings a federal employment discrimination claim against her employer, along with a related state-law claim for wrongful termination arising from the same firing. Even though the wrongful termination claim has no independent federal basis, supplemental jurisdiction lets the federal court hear it alongside the federal claim.

Since International Shoe, a court may exercise personal jurisdiction over a nonresident defendant with sufficient minimum contacts with the forum, such that jurisdiction doesn’t offend fair play and substantial justice. Two flavors: general jurisdiction (any claim, but only where the defendant is truly “at home” — for a corporation, essentially its state of incorporation and principal place of business) and specific jurisdiction (narrower — only claims arising out of or relating to the defendant’s own forum contacts, requiring purposeful availment).

International Shoe Co. v. Washington, 326 U.S. 310 (1945), is the case that replaced the older, rigid rule requiring a defendant’s physical presence within a state (or actual consent) with the modern minimum-contacts standard. A shoe manufacturer incorporated and headquartered in Missouri employed salesmen who worked out of Washington State, soliciting orders that were sent back to Missouri for approval and shipment; the company had no office, no warehouse, and no contracts formally executed inside Washington at all. When Washington tried to collect unpaid state unemployment taxes from the company by serving one of its local salesmen, the company argued it wasn’t genuinely present in Washington under the old physical-presence rule. The Supreme Court upheld jurisdiction anyway, announcing that due process instead requires only that a defendant have such minimum contacts with the forum that maintaining the suit doesn’t offend “traditional notions of fair play and substantial justice” — a functional, contacts-based test that every personal jurisdiction case since has built on, including the general/specific jurisdiction framework this section covers.

Example. A company incorporated and headquartered entirely in Ohio, but that regularly ships products into Oregon, can likely be sued in Oregon only for claims arising from those Oregon sales (specific jurisdiction) — not for a completely unrelated claim having nothing to do with Oregon at all, since the company isn’t “at home” there.

Personal jurisdiction analysis is a two-step process: first, does the forum state’s own long-arm statute authorize jurisdiction as a matter of state law, and second, does exercising that jurisdiction independently satisfy constitutional due process? Beyond minimum contacts, traditional bases — consent, in-state service of process (“tag” jurisdiction), and domicile — can independently support jurisdiction too.

World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980), is the classic case testing exactly how much reach the due-process side of this analysis actually has. A family bought a car from a New York dealership and was later injured in an accident while driving through Oklahoma; they sued the New York dealership and regional distributor in Oklahoma courts, arguing it was foreseeable that a car sold in New York might eventually travel to Oklahoma. The Supreme Court held Oklahoma lacked personal jurisdiction over the New York-based defendants, because neither had purposefully availed itself of doing business in Oklahoma specifically — they sold no cars there, had no dealerships or agents there, and did nothing to serve that market. Mere foreseeability that a product might end up in a state through the unilateral choices of a customer isn’t enough; the defendant itself must have taken action purposefully directed at the forum. The case is the leading authority for why foreseeability alone, without the defendant’s own purposeful conduct reaching into the forum, can’t satisfy due process, no matter how predictable the eventual contact turns out to be.

Example. Even a defendant with no ongoing forum contacts at all can be subject to personal jurisdiction there if physically served with process while briefly passing through the state — traditional “tag” jurisdiction survives independently of the minimum contacts analysis.

Venue asks which specific federal district is the right place to file — distinct from jurisdiction. Under 28 U.S.C. § 1391, venue is proper where any defendant resides (if all reside in the same state) or where a substantial part of the events giving rise to the claim occurred. A proper case can still be transferred under § 1404(a) for convenience, or dismissed under forum non conveniens when a genuinely more appropriate forum (often a foreign one) exists.

Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981), is the leading modern forum non conveniens case, and it shows the doctrine reaching well beyond mere convenience for the parties. A small aircraft manufactured by an American company crashed in Scotland, killing several Scottish citizens; a legal representative filed suit in a U.S. federal court rather than in Scotland, in significant part because American tort law offered considerably more favorable damages rules than Scottish law did. The Supreme Court held the case should be dismissed in favor of litigation in Scotland — the location of the crash, the witnesses, and the evidence — and, importantly, ruled that the possibility of a less favorable choice-of-law outcome in the alternative forum ordinarily shouldn’t be given substantial weight in the forum non conveniens analysis at all. Otherwise, the Court reasoned, virtually every foreign plaintiff could defeat dismissal simply by pointing out that American law happened to favor them more, which would swallow the doctrine entirely. The case remains the reason forum non conveniens dismissals in international product liability and mass tort cases are relatively common, even where the U.S. venue would otherwise be perfectly proper.

Example. A car accident happens in Nevada between a Nevada plaintiff and a California defendant. Even though the defendant resides in California, venue is also proper in Nevada, since a substantial part of the underlying events (the accident itself) occurred there.