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What is “Subject-Matter Jurisdiction”?
Subject-matter jurisdiction refers to the types of cases (subject matter of the case) that a court can hear (preside over). For example, a superior court in a state may not be able to hear a family, probate, or taxation matter, because state law limits the court’s ability to do so. Instead, the state will create courts whose sole subject-matter jurisdiction is family, probate, or tax law. Similarly, a federal district court is charged with hearing criminal and civil cases. It may not hear bankruptcy or tax law cases. Congress created as special bankruptcy court and tax court with subject matter jurisdiction over those matters.
- Note: Subject matter jurisdiction is broken down into “general subject-matter jurisdiction” and “limited subject-matter jurisdiction”. A court of general subject-matter jurisdiction may hear any type of case that falls under the law of that jurisdiction (state or federal government). A court of limited jurisdiction, as discussed above, is limited to the specific types of cases that it can hear. This topic is broken down further below.
Federal and State Court Subject-Matter Jurisdiction
The subject-matter jurisdiction of a federal court is established by the US Constitution and Federal statutes. Similarly, the subject-matter jurisdiction of a state court is set by the state’s constitution.
- Relevant Law: ” federal court’s subject matter jurisdiction, constitutionally limited by article III, extends only so far as Congress provides by statute.” National Hospice Palliative Care v. Weems
Click the links for a more detailed explanation of:
Can a State Court Hear Federal Cases and Vice Versa?
Subject-matter jurisdiction is particularly important between federal and state trial courts. In some instances, a state trial court may not be able to hear certain federal matters, and vice versa. For example, money laundering is a federal crime. A state trial court generally cannot hear a case solely involving federal money-laundering charges, as it falls outside of its subject-matter jurisdiction. On the other hand, assault is a state law crime that is generally outside of the jurisdiction of the Federal District Court.
Click the links for more information on the ability of state courts to hear cases involving federal law and vice versa.
Can a State Court Case be Appealed to the Federal Court, and Vice Versa?
The issue arising again in matters of appeal. A state trial court may appeal to the intermediate state court of appeals or the state supreme court. A party in State Supreme Court case, can appeal to the US Supreme Court. This is the only time that a party can appeal a state court decision in federal appellate court. A party cannot appeal a state trial court decision in the Federal Circuit Court of Appeals. The court of appeals has no jurisdiction in this instance. Likewise, a party cannot appeal a Federal District Court case to a state court of appeals. The state court of appeals has no jurisdiction.
Click the link for more information on the subject-matter jurisdiction of state and federal appellate courts.
General Subject-Matter Jurisdiction
Some state courts have general subject-matter jurisdiction. This means that the state court has the authority to hear any type of case involving state law.
- Relevant Law: Federal District Courts are trial courts of limited jurisdiction. A State Superior Court is often a court of general jurisdiction. “Federal courts are courts of limited jurisdiction and unlike state courts, are not vested with “inherent” or “general” subject matter jurisdiction. Orthopaedic Surgery Assoc. v. Prudential Hlth. Care P.
- Example: The state superior court typically has authority to hear cases that are generally heard in lower-level courts. The reverse, however, is not true. Lower level courts (such as a municipal court) cannot hear cases that are outside of its limited, subject-matter jurisdiction.
Limited Subject-Matter Jurisdiction
Often state courts divide jurisdiction based on the following:
- the subject matter of a case,
- the amount in controversy (or possible penalty for a crime), or
- where individuals are located or reside.
Every state in the US has at least one court of general, subject-matter jurisdiction. Likewise, every state has some form of court with limited subject-matter jurisdiction.
Discussion: As stated above, the state superior court typically has general, subject-matter jurisdiction within the state. Do you believe it is important to have state courts of general jurisdiction? Why are courts of limited jurisdiction necessary?
- Courts of limited jurisdiction take some of the burden off of the state’s court of general jurisdiction (generally the Superior Court). There is an argument that it is absolutely necessary to have a court of general jurisdiction to avoid concentrating too much power in the lower courts of limited jurisdiction. Having the exclusive authority to hear certain types of cases would certainly cause a power shift.
Practice Question: Michelle hires Winston as a general contractor to build her home. Winston does a very sloppy job, which leads to Michelle suing him in state court for breach of contract and damages of $25,000. She sues in an intermediate trial court with a jurisdictional limit of $25,000. The court does not allow for a jury trial. Winston is not happy with the judge serving as trier of fact in the case. What may or should Winston do in this situation?
- Because every state has a court of general jurisdiction, Winston may ask that the case be dismissed or transferred to the state’s superior court of general jurisdiction. Here, the Constitutional safeguards of right to a jury trial will apply. Courts of limited jurisdiction often limit the right to a jury trial, as the parties always have the ability to have the case transferred to a higher trial court that grants that right.
Klerman, Daniel M., An Economic Analysis of Subject Matter Jurisdiction Waiver: A Response to Professor Buehler (August 24, 2014). 89 Washington Law Review Online 1 (2014); USC CLASS Research Paper No. 14-29; USC Law Legal Studies Paper No. 14-37. Available at SSRN: https://ssrn.com/abstract=2487445
Bellia Jr., Anthony J. and Clark, Bradford R., Kiobel, Subject Matter Jurisdiction, and the Alien Tort Statute (February 20, 2012). Notre Dame Legal Studies Paper No. 12-52; GWU Legal Studies Research Paper No. 2012-27. Available at SSRN: https://ssrn.com/abstract=2008254 or http://dx.doi.org/10.2139/ssrn.2008254
Parness, Jeffrey A., The Limits on Legislative Power to Withhold Subject Matter Jurisdiction (June 13, 2011). Illinois Bar Journal, Vol. 99, p. 316, June 2011. Available at SSRN: https://ssrn.com/abstract=1884944