Facts
- Plaintiffs sued FBI agents in federal district court seeking more than $3,000 in money damages.
- The complaint alleged that federal officers violated the Fourth Amendment by searching premises and seizing property without warrants.
- The complaint alleged that federal officers violated the Fifth Amendment by imprisoning plaintiffs and delaying presentment to a magistrate.
- The events arose from searches and arrests connected to mail-fraud indictments involving members of “Mankind United.”
- Defendants moved to dismiss for failure to state a claim and for summary judgment, asserting lawful authority and lawful arrests; the district court did not reach those motions.
- The district court dismissed on its own motion for lack of federal-question jurisdiction, concluding the action did not “arise under” the Constitution or federal law.
- The court of appeals affirmed and denied leave to amend to clarify the constitutional basis of the claims.
Issues
- Whether a federal district court has federal-question jurisdiction over a damages suit against federal officers alleging direct violations of the Fourth and Fifth Amendments.
- Whether the absence of an express constitutional or statutory damages remedy defeats jurisdiction, or instead presents a merits question.
Decision
- The Supreme Court reversed and remanded.
- The Court held that federal-question jurisdiction exists when the complaint seeks recovery directly under the Constitution or federal law.
- Jurisdiction is absent only if the federal claim is immaterial and asserted solely to obtain jurisdiction, or is wholly insubstantial and frivolous.
- Whether the Constitution supplies a damages cause of action is a merits question to be decided after the court assumes jurisdiction.
Legal Principles
- A complaint invoking the Constitution as the source of the right asserted generally invokes federal-question jurisdiction, even if the same facts could support state-law claims.
- The existence of subject-matter jurisdiction is distinct from whether the plaintiff has stated a claim upon which relief can be granted.
- Lack of an express damages remedy in the constitutional text or in statutes does not, by itself, eliminate federal jurisdiction over a nonfrivolous constitutional claim.
- Federal courts must entertain colorable constitutional claims unless the asserted federal ground is a sham or patently frivolous.
Conclusion
The Court held that federal courts have jurisdiction over nonfrivolous suits seeking money damages directly for alleged Fourth and Fifth Amendment violations by federal officers, and that any question whether such a damages remedy exists must be resolved on the merits rather than by dismissing for lack of jurisdiction.