Subject Matter Jurisdiction
From Florida Legal Wiki
Subject Matter Jurisdiction refers to a Courts authority to hear a legal case based on the substance (subject matter) at the center of the dispute. This is distinct from personal jurisdiction which assigns a Courts jurisdiction to a case based on the acts and contacts of the defendant within the forum state.
In order to hear the case, a Court must have both subject matter jurisdiction over the controversy and personal jurisdiction over the defendant. Unlike personal jurisdiction, subject matter jurisdiction cannot be waived by acquiescence of the parties, or otherwise. See i.e. Florida Export Tobacco Co. v. Dep't of Revenue, 510 So.2d 936, 943 (Fla. 1st DCA 1987).
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[edit] State Subject Matter Jurisdiction
Florida's Circuit Courts are courts of general jurisdiction. The State Legislature has created statutes that delineate jurisdiction within the various divisions of the circuit court, for instance, a family court has jurisdiction over family law issues that arise in the State, but not civil or criminal law issues. This is known as Divisional Jurisdiction and is distinct from subject matter jurisdiction.
Circuit courts have subject matter jurisdiction over claims where the amount in controversy exceeds $15,000 and over appeals from County Court.
Small Claims courts have a more limited subject matter jurisdiction. The amount in controversy must be less than $5,000 and the court cannot, for instance, issue injunctions.
County courts can hear all matters where the amount in controversy is below $15,000.
District Courts of Appeal have subject matter jurisdiction over appeals from Circuit Court, see Florida Rule of Appellate Procedure 9.030, and over certain Extraordinary Writs, which are original actions, not appeals, see Florida Rule of Appellate Procedure 9.100.
State Courts cannot hear some Federal Question cases where there is exclusive federal jurisdiction (anti-trust, federal securities, patent, bankruptcy, etc.)
[edit] Declaratory Judgment
Chapter 86, Fla. Stat., provides that Florida Courts have broad subject matter jurisdiction to resolve claims seeking Declaratory Judgment. The Florida Legislature has expressed its intent that the Court's authority in this area is to be broadly construed. In order for the Court to have subject matter jurisdiction there must exist (1) a justiciable controversy (2) between adverse parties. Martinez v. Scanlon, 582 So.2d 1167, 1170-71 (Fla. 1991).
[edit] Federal Subject Matter Jurisdiction
Article III section 2 of the [U.S. Constitution] outlined the limits of Federal judicial power and jurisdiction.
The three most important categories of Subject Matter Jurisdiction are Diversity Jurisdiction, Supplemental Jurisdiction, and Federal Question Jurisdiction.
[edit] Diversity Jurisdiction
Federal District Courts will have original jurisdiction over a legal dispute when the parties to that dispute are citizens of separate states, and when the amount in controversy exceeds $75,000 USD.
To meet the amount in controversy minimum threshold, a single plaintiff can add up all claims against a single defendant, but not against multiple defendants, unless those defendants are joint owners to a piece of property that is the subject of the dispute (in effect functioning as a single defendant).
[edit] Citizenship
Individual - An individual is a citizen in the state that they are born or spend the majority of their time, are documented by a State authorized drivers license as residing in the state, have a primary residence listed in the state, or subjectively, where that individual declares they are a citizen and possess the intent to maintain a permanent home. A Court will look at the relevant facts in totality to determine the citizenship of the individual.
A person who is not a resident of a state or designated area, even if he or she is a U.S. citizen, cannot satisfy the diversity of citizenship requirement and therefore cannot bring an action under the Diversity Clause in a Federal Court.
Corporation - 28 USC 1332 (c) (1) - A Corporation is a citizen of any State by which it has been incorporated and of the State where it has it's principal place of business. Generally, a Corporations principle place of business is determined by applying the Nerve Center Test. See Hertz.
-The Nerve Center Test identifies the principle place of business where high-level officers direct, control, and otherwise coordinate the corporations activities.
Complete Diversity Rule - There is no diversity of jurisdiction if ANY plaintiff to a suite shares citizenship with any defendant to the suite. Just one overlap of citizenship will destroy diversity jurisdiction.
A(Florida citizen) & B (Georgia citizen) v. C (Florida citizen) on a breach of contract claim for $100,000 = OVERLAP OF CITIZENSHIP, CLAIM IN EXCESS OF $75,000 and NO DIVERSITY JURISDICTION UNDER 28 USC 1332.
A(Florida citizen) & B (Arizona Citizen) v. C(Wyoming citizen) on a breach of contract claim for $100,000 - COMPLETE DIVERSITY OF CITIZENSHIP, CLAIM IN EXCESS OF $75,000 AND DIVERSITY JURISDICTION UNDER 28 USC 1332.
Decedent Rule - 28 USC 1332 (c)(2) -The legal representative of the estate of a decedent shall be deemed to be a citizen only of the same State as the decedent.
Infant or Incompetent Citizenship 28 USC 1332 (c)(2) - The legal representative of an infant of incompetent shall be deemed to be a citizen only of the same State as the infant or incompetent.
[edit] Federal Question Jurisdiction
Prior to 1878, questions of Federal law were answered by the State Courts exclusively. Following the implementation 28 USC 1331, the "Federal District Courts have original jurisdiction over all civil actions arising under the Constitution, laws, or treaties of the United States of America."
Well-Pleaded Complaint Rule
The Court will review the Plaintiffs complaint to ensure that the legal theories stated in the complaint, pertain only to the plaintiff, and not to the legal challenges that a defendant might raise during the course of litigation. If there are extraneous, defense related aspects to the Plaintiffs complaint, then the Court will dismiss the case.
Automatic Federal Question cases: -Bankruptcy -Nuclear Power -ERISA
[edit] Supplemental Jurisdiction
Section 1367 (a) of the Federal Rules of Civil Procedure provides that the District Court shall have supplemental jurisdiction over all claims outside of its jurisdiction that are related to the primary claim to the extent that they form the same case or controversy under Article III of the United States Constitution.
The relation of the supplemental claims to the primary claim must be such that "...the claims share a common nucleus of operative fact..." United Mine Workers v. Gibbs SITE
Exceptions to Supplemental Jurisdiction 1367 (b)
Any civil action where the district courts have jurisdiction over a controversy, that is based only on section 1332 (Diversity Jurisdiction), DEVELOP.
within such original jurisdiction that they form part of the same case or controversy under Article III of the United States. )The question of whether or not additional claims can be attached is always discretionary.
Discretion of the Courts with Supplemental Jurisdiction 1367 (c)
The district courts may decline to exercise supplemental jurisdiction over a claim if:
(1) The claim raises a novel or complex issue of State law (2) The claim substantially predominates over the claim or claims over which the district Court has original jurisdiction. (3) The district Court has dismissed all claims over which it has original jurisdiction, or (4) In exceptional circumstances, there are other compelling reasons for declining jurisdiction
