Facts
- A mother, acting on behalf of her two minor daughters, filed a federal diversity action seeking money damages.
- The defendants were the children’s father and his companion, citizens of a different state than the plaintiff.
- The complaint alleged sexual and physical abuse of the children by the father and that the companion aided or permitted the abuse.
- The suit asserted only state-law tort claims and did not request a divorce, alimony, or child-custody decree.
Issues
- Whether a “domestic relations exception” limits federal diversity jurisdiction, and if so, whether it bars a tort action seeking only money damages between family members.
- Whether the federal court could dismiss or abstain under Younger-type abstention principles in this diversity tort action.
Decision
- The Supreme Court reversed and remanded.
- The Court held that a domestic relations exception exists as a matter of statutory construction, but it is limited to cases seeking issuance of a divorce, alimony, or child-custody decree.
- Because the complaint sought only monetary relief for alleged torts and did not seek a status decree, diversity jurisdiction under 28 U.S.C. § 1332 was proper.
- Younger abstention did not justify dismissal because there were no qualifying ongoing state proceedings warranting abstention.
Legal Principles
- The domestic relations exception to federal diversity jurisdiction is a statutory, not constitutional, limitation.
- The exception is narrowly confined to actions requesting divorce, alimony, or child-custody decrees; it does not bar federal jurisdiction over tort claims for damages merely because the dispute arises from family relationships.
- In statutory-interpretation settings, stare decisis has special force where Congress can revise jurisdictional statutes and has long acquiesced in a settled judicial construction.
- Younger abstention requires a qualifying ongoing state judicial proceeding and other prerequisites; absent such conditions, dismissal of a diversity tort action on Younger grounds is improper.
Conclusion
Federal courts have diversity jurisdiction over tort damages actions between family members when the plaintiff does not seek a divorce, alimony, or custody decree, and abstention is not warranted without the type of ongoing state proceedings required by Younger.