Bell v. Hood

Brief Fact Summary.

Bell (Plaintiff) and others sued Hood (Defendant) and other federal agents for damages for violation of Plaintiff’s Fourth and Fifth Amendment rights. The suit was dismissed by the federal district court for lack of jurisdiction.

Synopsis of Rule of Law.

When a complaint seeks recovery under federal law or the Constitution, a federal court must first assume jurisdiction before determining whether the complaint states a cause of action upon which relief may be granted.

Facts.

Plaintiff and others brought an action in federal court against Defendant and other FBI agents seeking more than $3000 for violations of the Fourth and Fifth Amendments to the Constitution. The district court dismissed the complaint as one not arising under the Constitution or federal law. Plaintiff appealed.

Issue.

Does a federal court have jurisdiction over a complaint alleging a federal question when no remedy appears to exist?

Held.

(Black, J.) Yes. When a complaint seeks recovery under federal law or the Constitution, a federal court must first assume jurisdiction before determining whether the complaint states a cause of action upon which relief may be granted. Plaintiff clearly sought to invoke federal question jurisdiction by alleging violations of the Fourth and Fifth Amendments in his complaint. Although the court may ultimately determine that no remedy exists for these violations and enter a judgment on the merits, the court must first assume jurisdiction to consider the question of remedy.  

Dissent.

(Stone, C.J.) Jurisdiction arises when there is a cause of action under the Constitution or federal law.  When neither provides for the remedy sought in a complaint, there is no federal claim and therefore no federal jurisdiction.

Discussion.

Federal question jurisdiction is raised when the complaint involves questions arising under the Constitution or federal law. Osborn v. Bank of the United States, 22 U.S. 738 (1924) laid out two criteria for establishing federal question jurisdiction. First, the federal question must be part of the original cause of action and, second, the question must be one that is within the power of Congress to create federal jurisdiction over.