Brief Fact Summary. Petitioner sought to bring a federal tortious action against respondents for the abuse of her children based on diversity-of-citizenship. The district court dismissed the action based on the domestic relations exception to diversity jurisdiction.
Synopsis of Rule of Law. The domestic relations exception to diversity jurisdiction applies only to the power of the federal courts to issue divorce, alimony, or child custody decrees.
The Congressional power to ordain and establish inferior courts includes the power of investing them with jurisdiction either limited, concurrent, or exclusive, and of withholding jurisdiction from them in the exact degrees and character which to the Congress may seem proper for the public good.View Full Point of Law
Issue. Is there a domestic relations exception to federal jurisdiction, and if such an exception exists, does it permit a district court to abstain from exercising diversity jurisdiction in a tort action for damages?
Held. Federal subject-matter jurisdiction is proper in this case pursuant to Section:1332 because the domestic relations exception encompasses only cases involving the issuance of a divorce, alimony, or child custody decree.
Previous federal precedent disclaimed any jurisdiction upon the subject of divorce, or for the allowance of alimony. Although technically dicta, this formed the basis for excluding domestic relations cases. Because this rule has been recognized for nearly a century and a half, the Court will continue to recognize the limitation.
The Constitution does not exclude domestic relations cases. It exists as a matter of statutory construction not based on historical justifications, but rather on Congress’ apparent acceptance of this construction. However, this limitation on jurisdiction applies only to the power of the federal courts to issue divorce, alimony, or child custody decrees.
Discussion. The domestic relations exception applies even in cases where the plaintiffs establish the requisite diversity of citizenship and amount in controversy.