Strawbridge v. Curtiss
7 U.S. 267, 2 L. Ed. 435 (1806)
Strawbridge, who was a citizen
of Massachusetts, sued Curtiss (who was a citizen of Vermont), and other
few other people who were citizens of Massachusetts.
Strawbridge sued in Federal
Court based on diversity of citizenship.
The Federal Trial Court dismissed the case
based on lack of subject matter jurisdiction. Strawbridge appealed.
Strawbridge argued that he
was a citizen of Massachusetts and Curtiss was a citizen of Vermont.
Therefore there was diversity of citizenship.
Curtiss argued that the
plaintiff and some of the defendants were all citizens of Massachusetts,
therefore there was not diversity of citizenship.
The Federal Appellate Court affirmed.
The Appellate Court found
that you need complete diversity
in order to have subject matter jurisdiction. Even one defendant who is
from the same State as the plaintiff, destroys diversity.
Strawbridge was a resident of Massachusetts, if any of the defendants were residents of
Massachusetts, then there isn't complete diversity and the suit cannot be brought to
Federal court under the theory of diversity jurisdiction.
Federal courts are courts of
limited jurisdiction. That means they can't hear any case, they can only
hear cases brought because there is a federal law at issue (federal
question jurisdiction) or there is diversity
See 28 U.S.C. 1332.
The concept of complete
diversity is a construction of an act
of Congres, not part of the Constitution. The Constitution only requires
Congress has enacted a few
Statutes that establish times when you don't need complete diversity to
sue in a Federal Court. (Certain types of class action lawsuits for