Facts
- George Capron filed a tort action (trespass on the case) against Hadrianus Van Noorden in the United States Circuit Court for the District of North Carolina.
- Capron’s pleading did not allege facts establishing federal subject-matter jurisdiction, including whether either party was an alien or whether the parties were citizens of different states.
- The case was tried on the general issue, and the jury returned a verdict for Van Noorden.
- The circuit court entered judgment for Van Noorden.
- Capron sought Supreme Court review by writ of error, arguing the circuit court lacked subject-matter jurisdiction because the record did not show any jurisdictional basis.
Issues
- Whether a federal circuit court judgment is erroneous when the record does not affirmatively show facts establishing subject-matter jurisdiction (particularly diversity of citizenship).
- Whether a plaintiff who chose the federal forum may seek reversal after losing by asserting that the federal court lacked subject-matter jurisdiction due to missing jurisdictional allegations.
Decision
- The Supreme Court reversed the circuit court’s judgment.
- The Court held that federal circuit courts are courts of limited jurisdiction and their jurisdiction must affirmatively appear on the face of the record.
- The Court permitted the plaintiff who invoked federal court to assign as error the absence of subject-matter jurisdiction, notwithstanding that the defect arose from the plaintiff’s own pleading omission.
Legal Principles
- Federal courts are courts of limited jurisdiction; subject-matter jurisdiction cannot be presumed.
- When jurisdiction depends on diversity (or alienage), the pleadings and record must show the parties’ citizenship (or alien status) in a way that establishes the statutory basis for jurisdiction.
- Subject-matter jurisdiction is not waivable and cannot be created by consent, omission, or litigation conduct.
- A judgment entered without subject-matter jurisdiction is reversible even if the jurisdictional defect is raised only after an adverse verdict and even by the party who initiated the federal action.
Conclusion
Because the record failed to allege facts establishing federal subject-matter jurisdiction, the circuit court lacked authority to adjudicate the case, and the Supreme Court reversed, confirming that federal jurisdiction must be shown on the record and may be challenged at any stage by any party, including the plaintiff who filed in federal court.