Lawsuits & Legal Procedures Supreme Court Cases
The Federal Rules of Civil Procedure govern each stage of a lawsuit in federal court, from the initial complaint and pre-trial motions to trial and judgment. Some of the key rules include:
- Rule 8(a): the initial claim for relief
- Rule 12(b): pre-trial motions on grounds such as lack of jurisdiction, improper venue, insufficient service of process, or failure to state a claim
- Rule 13: counterclaims (against an opponent) and cross-claims (against a co-party)
- Rule 23: class actions brought by groups of people who have suffered similar harms
- Rule 56: summary judgment, when the court rules for one party as a matter of law rather than proceeding to trial
In addition to interpreting the Federal Rules, the Supreme Court has applied federal statutes and constitutional principles to legal procedures. For example, due process has shaped theories of personal jurisdiction, which is the power of a court to make decisions that bind a party to a lawsuit. A court also must hold subject matter jurisdiction over a case. For federal courts, this usually requires diversity jurisdiction or federal question jurisdiction, which are defined by the U.S. Code. Diversity jurisdiction involves the parties and the amount in controversy, while subject matter jurisdiction involves the legal basis for the dispute.
The Supreme Court also has addressed complex issues related to conflicts of laws and preclusion. A conflict of laws occurs when a case has a connection to two or more jurisdictions with different applicable laws. Preclusion may consist of res judicata (claim preclusion) or collateral estoppel (issue preclusion). Res judicata prevents claims that have been litigated or could have been litigated from being litigated again, while collateral estoppel prevents issues that have been litigated from being litigated again.
It is the duty of a court to see that it has jurisdiction. The consent of parties cannot provide it.
Strawbridge v. Curtiss (1806)
If there are two or more joint plaintiffs and two or more joint defendants, each of the plaintiffs must be capable of suing each of the defendants in federal courts for diversity jurisdiction.
Pennoyer v. Neff (1878)
Proceedings to determine the personal rights and obligations of parties over whom the court has no jurisdiction do not constitute due process.
Shoshone Mining Co. v. Rutter (1900)
The mere fact that a suit is an adverse suit authorized by the statutes of Congress is not sufficient by itself to vest jurisdiction in the federal courts.
Louisville & Nashville R. Co. v. Mottley (1908)
Federal question jurisdiction cannot be based on an alleged anticipated defense.
Erie Railroad Co. v. Tompkins (1938)
A federal court exercising diversity jurisdiction must apply the state law as declared by the highest state court. There is no federal general common law.
Hansberry v. Lee (1940)
A judgment rendered in a class suit may be res judicata as to members of the class who are not formal parties to the suit. There is a failure of due process only in cases in which it cannot be said that the procedure adopted fairly ensures the protection of the interests of absent parties who are to be bound by it.
Klaxon Co. v. Stentor Electric Manufacturing Co., Inc. (1941)
Federal courts deciding questions of conflict of laws in diversity of citizenship cases must follow the rules prevailing in the states in which they sit.
International Shoe Co. v. Washington (1945)
To subject a defendant to personal jurisdiction when they are not present in the territory of the forum, the defendant must have certain minimum contacts with the forum such that the maintenance of the lawsuit does not offend traditional notions of fair play and substantial justice.
Hickman v. Taylor (1947)
Memoranda, statements, and mental impressions prepared or obtained from interviews with witnesses by counsel in preparing for litigation after a claim has arisen are not within the attorney-client privilege. However, a party who would invade the privacy of an attorney’s course of preparation must establish adequate reasons to justify production through a subpoena or court order.
Gulf Oil Corp. v. Gilbert (1947)
Important considerations in the application of the forum non conveniens doctrine from the standpoint of litigants are relative ease of access to sources of proof, availability of compulsory process for attendance of unwilling witnesses, cost of obtaining attendance of willing witnesses, the possibility of viewing the premises if appropriate, and other practical problems that make trial of a case easy, expeditious, and inexpensive. Considerations of public interest include the undesirability of piling up litigation in congested centers, the burden of jury duty on people of a community with no relation to the litigation, the local interest in having localized controversies decided at home, and the unnecessary injection of problems in conflict of laws. (Forum non conveniens allows a court to dismiss a case when another court is clearly better positioned to hear it.)
Conley v. Gibson (1957)
A complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that the plaintiff can prove no set of facts in support of their claim that would entitle them to relief.
Beacon Theatres, Inc. v. Westover (1959)
Only under the most imperative circumstances can the right to a jury trial of legal issues be lost through prior determination of equitable claims.
Hoffman v. Blaski (1960)
A federal district court in which a civil action has been properly brought is not empowered to transfer the action on the motion of the defendant to a district in which the plaintiff did not have a right to bring it.
Van Dusen v. Barrack (1964)
When actions were properly brought in the transferor district court, and the defendants seek transfer under Section 1404(a), the change of venue should not be accompanied by a change in the governing state laws.
United Mine Workers of America v. Gibbs (1966)
Pendent jurisdiction exists whenever there is a substantial federal claim, and the relationship between the federal claim and the asserted state claims permits the conclusion that the entire action before the court comprises one case. The state and federal claims must derive from a common nucleus of operative fact.
Adickes v. S.H. Kress & Co. (1970)
A party moving for summary judgment has the burden of showing the absence of a genuine issue as to any material fact. For these purposes, the material submitted by the moving party must be viewed in the light most favorable to the opposing party.
Blonder Tongue v. University of Illinois Foundation (1971)
Res judicata and collateral estoppel are affirmative defenses that must be pleaded to give the opposing party notice of the plea of estoppel and a chance to argue why the imposition of estoppel would be inappropriate.
The Bremen v. Zapata Off-Shore Co. (1972)
A forum selection clause that was a vital part of a towing contract was binding unless the party challenging its enforcement could meet the heavy burden of showing that its enforcement would be unreasonable, unfair, or unjust. (A forum selection clause is a contract provision stipulating that disputes arising under the contract must be heard in a certain court.)
Liberty Mutual Insurance Co. v. Wetzel (1976)
An order constituting a grant of partial summary judgment limited to liability cannot be considered final when damages or other relief remain to be resolved.
Aldinger v. Howard (1976)
A non-federal claim should not be the basis for joining a party over whom no independent federal jurisdiction exists, simply because that claim derives from the common nucleus of operative fact giving rise to the dispute between the parties to the federal claim.
Shaffer v. Heitner (1977)
When the property serving as the basis for state court jurisdiction is completely unrelated to the plaintiff’s cause of action, the presence of the property alone does not support jurisdiction without other ties among the defendant, the state, and the litigation.
Owen Equipment and Erection Co. v. Kroger (1978)
A finding that federal and non-federal claims arise from a common nucleus of operative fact does not suffice to establish that a federal court has the power to hear non-federal as well as federal claims. Although the constitutional power to adjudicate the non-federal claim may exist, it does not necessarily follow that statutory authorization has been granted. The context in which a non-federal claim is asserted is crucial.
Parklane Hosiery Co., Inc. v. Shore (1979)
A trial judge should not allow the use of offensive collateral estoppel if a plaintiff could easily have joined in the earlier action, or if the application of offensive estoppel would be unfair to the defendant. Unfairness might be found when the defendant had less incentive to defend the previous case, there are inconsistent judgments, or different procedural opportunities in the second action could cause a different result. (Offensive collateral estoppel is collateral estoppel asserted by a plaintiff.)
World-Wide Volkswagen Corp. v. Woodson (1980)
The foreseeability that is critical to due process analysis for personal jurisdiction is that the defendant’s conduct and connection with the forum are such that they should reasonably anticipate being brought into court there.
Allstate Insurance Co. v. Hague (1981)
A state court could apply the law of its state when the state had a significant aggregation of contacts with the parties and the occurrence, creating state interests, such that the application of its law was neither arbitrary nor fundamentally unfair.
Upjohn Co. v. U.S. (1981)
The attorney-client privilege exists to protect not only the giving of professional advice to those who can act on it, but also the giving of information to the lawyer to enable them to give sound and informed advice. However, the privilege only protects disclosure of communications, rather than disclosure of the underlying facts.
Piper Aircraft Co. v. Reyno (1981)
Plaintiffs may not defeat a motion to dismiss on the ground of forum non conveniens merely by showing that the substantive law that would be applied in the alternative forum is less favorable to them than the law of the chosen forum.
Insurance Corp. of Ireland v. Compagnie des Bauxites (1982)
Since the requirement that a court have personal jurisdiction protects an individual interest, it may be intentionally waived, or a defendant may be estopped from raising the issue for various reasons.
Helicopteros Nacionales v. Hall (1984)
Mere purchases, even if occurring at regular intervals, are not enough to warrant a state’s assertion of personal jurisdiction over a non-resident corporation in a cause of action not related to the purchases.
Cooper v. Federal Reserve Bank of Richmond (1984)
A judgment in a class action determining that an employer did not engage in a general pattern or practice of racial discrimination against the certified class of employees does not preclude a class member from maintaining a subsequent civil action alleging an individual claim of racial discrimination against the employer.
Burger King Corp. v. Rudzewicz (1985)
A contract with an out-of-state party does not alone automatically establish sufficient minimum contacts for personal jurisdiction in the other party’s home forum. Instead, the court must evaluate the prior negotiations, the contemplated future consequences, the terms of the contract, and the parties’ actual course of dealing to determine whether a defendant purposefully established minimum contacts within the forum.
Phillips Petroleum Co. v. Shutts (1985)
Due process requires that class members in a class action receive notice, an opportunity to appear in person or by counsel, an opportunity to opt out, and adequate representation. It does not require that absent class members affirmatively opt in to the class.
Matsushita Electrical Industrial Co., Ltd. v. Zenith Radio Corp. (1986)
The absence of any plausible motive to engage in the conduct charged is highly relevant to whether a genuine issue for trial exists within the meaning of Rule 56(e) on summary judgment. Lack of motive bears on the range of permissible conclusions that might be drawn from ambiguous evidence.
Anderson v. Liberty Lobby, Inc. (1986)
The inquiry involved in a ruling on a motion for summary judgment or for a directed verdict necessarily implicates the substantive evidentiary standard of proof that would apply at the trial on the merits.
Celotex Corp. v. Catrett (1986)
Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.
Merrell Dow Pharmaceuticals, Inc. v. Thompson (1986)
A violation of a federal statute as an element of a state cause of action does not state a claim arising under federal law when Congress has determined that there should be no private federal cause of action for the violation.
Asahi Metal Industry Co. v. Superior Court (1987)
The substantial connection between a defendant and the forum state necessary for a finding of minimum contacts that support personal jurisdiction must derive from an action purposely directed toward the forum state. The mere placement of a product into the stream of commerce is not such an act, even if done with an awareness that the stream will sweep the product into the forum state, without additional conduct indicating an intent to serve the forum state market.
Martin v. Wilks (1989)
A voluntary settlement in the form of a consent decree between one group of employees and their employer cannot possibly settle the conflicting claims of another group of employees who do not join in the agreement.
Chauffeurs Local 391 v. Terry (1990)
To determine whether a particular action will resolve legal (as opposed to equitable) rights, such that the plaintiff is entitled to a jury trial, courts must examine both the nature of the issues involved and, more importantly, the remedy sought.
Burnham v. Superior Court (1990)
Service of process confers state court jurisdiction over a physically present non-resident, regardless of whether they were only briefly in the state or whether the cause of action is related to their activities there.
Carnival Cruise Lines, Inc. v. Shute (1991)
A non-negotiated forum clause in a passage contract may be enforceable even though it is not the subject of bargaining, although it is subject to judicial scrutiny for fundamental fairness.
Edmonson v. Leesville Concrete Co., Inc. (1991)
A private litigant in a civil case may not use peremptory challenges to exclude jurors on account of race.
J.E.B. v. Alabama ex rel. T.B. (1994)
The Equal Protection Clause prohibits discrimination in jury selection on the basis of gender, or on the assumption that an individual will be biased in a particular case solely because that person happens to be a woman or a man.
Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing (2005)
In determining jurisdiction over federal issues embedded in state law claims between non-diverse parties, the question is whether the state law claim necessarily raises a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities.
Exxon Mobil Corp. v. Allapattah Services, Inc. (2005)
When the other elements of jurisdiction are present, and at least one named plaintiff in the action satisfies the amount-in-controversy requirement for diversity jurisdiction, Section 1367 authorizes supplemental jurisdiction over claims of other plaintiffs in the same case or controversy, even if their claims are for less than the requisite amount.
Scott v. Harris (2007)
When opposing parties tell two different stories, one of which is blatantly contradicted by the record so that no reasonable jury could believe it, a court should not adopt that version of the facts for the purposes of ruling on a motion for summary judgment.
Bell Atlantic Corp. v. Twombly (2007)
A plaintiff must plead enough facts to state a claim to relief that is plausible on its face.
Taylor v. Sturgell (2008)
The rule against non-party preclusion is subject to six categories of exceptions: when a party agreed to be bound by the determination of issues in an action between others; when there was a pre-existing substantive legal relationship between the person to be bound and a party to the judgment; when the non-party was adequately represented by someone with the same interests who was a party to the earlier action; when the non-party assumed control over the litigation in which the judgment was rendered; when a party bound by a judgment tries to relitigate through a proxy; and when a special statutory scheme consistent with due process expressly forecloses successive litigation by non-litigants.
Ashcroft v. Iqbal (2009)
The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.
Hertz Corp. v. Friend (2010)
For the purposes of federal diversity jurisdiction, a corporation's principal place of business refers to the place where its high level officers direct, control, and coordinate the corporation’s activities. (This is known as its nerve center.)
Wal-Mart Stores, Inc. v. Dukes (2011)
A class in a proposed class action has common questions of law or fact if their claims depend on a common contention of such a nature that it is capable of classwide resolution, which means that determination of its truth or falsity will resolve an issue that is central to the validity of each of the claims in one stroke.
J. McIntyre Machinery, Ltd. v. Nicastro (2011)
Generally, the exercise of judicial power is not lawful unless the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws. A foreign manufacturer was not subject to personal jurisdiction when it did not target the state in any relevant sense.
Goodyear Dunlop Tires Operations, S.A. v. Brown (2011)
Ties serving to bolster the exercise of specific jurisdiction do not warrant a determination that, based on those ties, the forum has general jurisdiction over a defendant.
BNSF Railroad Co. v. Tyrrell (2017)
A court may assert general jurisdiction over out-of-state corporations to hear any and all claims against them when their affiliations with the state are so continuous and systematic as to render them essentially at home in the forum state.
Bristol-Myers Squibb Co. v. Superior Court of California (2017)
When there is no connection between the forum and the underlying controversy, specific jurisdiction is lacking regardless of the extent of a defendant’s unconnected activities in the state.
Ford Motor Co. v. Montana Eighth Judicial District Court (2021)
When a company serves a market for a product in a state, and that product causes an injury in the state to one of its residents, the state’s courts may entertain the resulting lawsuit.
