Strawbridge v. Curtiss

7 U.S. 267 (1806)

One-Sentence Takeaway: A controversy is not between “citizens of different states,” so as to give subject matter jurisdiction to the federal courts, unless all the persons on one side of it are citizens of different states from all the persons on the other side.

Summary: Plaintiff, a resident of Massachusetts, brought action against Defendant, a resident of Vermont, and other Defendants, residents of Massachusetts. The case was filed in a federal court based on diversity of citizenship.

The district court dismissed the case for lack of diversity jurisdiction and Plaintiff appealed.

The issue facing the United States Supreme Court was whether a federal court has subject matter jurisdiction when one defendant is from a different state but other defendants are from the same state as the Plaintiff.  The Court ruled in the negative.

The Court reasoned that complete diversity was required in order for a federal court to have subject matter jurisdiction based on diversity.  Even one of the many defendants who is from the same state as the plaintiff destroys diversity.

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