Capron v. Van Noorden – Case Brief
Capron v. Van Noorden, 6 US 126, 2 Cranch 126 (1804).
Facts: Capron (P) sued Van Noorden (D) in federal district court. The complaint did not establish the that either of the parties was an alien or a citizen of North Carolina or a citizen of another state. The case was for trespass on the case and there was no federal question. The case could only be heard in federal court if it were based on diversity. The court heard the case nevertheless and entered judgment in favor of Van Noorden. Capron appealed on the basis that the court did not have jurisdiction because diversity had not been established.
Issue: May a party consent to jurisdiction in a federal court if diversity otherwise does not exist? When can challenges to subject matter jurisdiction be raised?
Holding and Rule: A party cannot consent to jurisdiction in a federal court if no actual diversity exists. Challenges to subject matter jurisdiction can be raised at any time prior to final judgment. Federal courts are courts of limited jurisdiction and here there was no jurisdiction upon which the court could take the case. This is a limitation imposed on the court by the Constitution and cannot be waived by the parties.
Notes: A federal court must dismiss a case for lack of subject matter jurisdiction even if the matter is raised for the first time on appeal. Jurisdiction is a matter that can be raised sua sponte by the trial court or court of appeals.