3.1 Federal Question Jurisdiction

Federal question jurisdiction lets federal courts hear cases involving federal law. It stems from the Constitution's "arising under" clause and ensures uniform interpretation nationwide. Congress can limit this jurisdiction within constitutional bounds.

The main statute, 28 U.S.C. § 1331, grants federal courts jurisdiction over cases arising from U.S. laws or treaties. The well-pleaded complaint rule requires the federal question to appear in the plaintiff's initial filing, not in anticipated defenses.

Federal Question Jurisdiction

Constitutional Basis and Purpose

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• Federal question jurisdiction empowers federal courts to hear cases involving federal law issues established by Article III, Section 2 of the U.S. Constitution
• "Arising under" clause in Article III extends judicial power to cases involving the Constitution, laws, and treaties of the United States
• Ensures uniform interpretation and application of federal law nationwide
• Constitutional federal question jurisdiction broader than statutory counterpart allows Congress to limit actual jurisdiction granted to federal courts
• Distinct from diversity jurisdiction based on parties' citizenship

Scope and Limitations

• Form of subject matter jurisdiction separate from diversity jurisdiction
• Congress can restrict federal courts' jurisdiction within constitutional limits
• Broader constitutional basis allows flexibility in legislative implementation
• Balances federal and state court roles in interpreting federal law
• Promotes consistency in federal law application across different states

Statutory Requirements for Federal Question Jurisdiction

28 U.S.C. § 1331 Provisions

• Grants federal district courts original jurisdiction over federal question cases
• Covers civil actions arising under the Constitution, laws, or treaties of the United States
• Well-pleaded complaint rule requires federal question to appear on face of plaintiff's properly pleaded complaint
• Anticipatory defenses or counterclaims based on federal law insufficient to establish jurisdiction
• Amount in controversy requirement eliminated in 1980 (previously $10,000 minimum)

Supplemental Jurisdiction and Related Claims

• 28 U.S.C. § 1367 allows federal courts to hear related state law claims in federal question cases
• Supplemental jurisdiction extends to claims forming part of the same case or controversy
• Enables efficient resolution of related issues in a single forum
• Courts may decline supplemental jurisdiction in certain circumstances (novel or complex state law issues)
• Promotes judicial economy by allowing comprehensive adjudication of related claims

Cases Arising Under Federal Law

"Arising Under" Test

• Statutory "arising under" test narrower than constitutional counterpart
• Case arises under federal law when federal law creates plaintiff's cause of action
• Federal issue in state law claim may suffice for jurisdiction under specific criteria
• Supreme Court's Grable test requires federal issue to be actually disputed, substantial, and resolvable in federal court without disrupting federal-state balance
• Mere reference to federal law or need for interpretation generally insufficient
• Substantiality requirement ensures only cases with significant federal interests qualify

Examples and Applications

• Federal causes of action automatically satisfy "arising under" requirement (Civil Rights Act claims, patent infringement suits)
• State law claims with embedded federal issues require nuanced analysis (state law claim questioning validity of federal agency action)
• Grable case involved state quiet title action with embedded federal tax law issue
• Merrell Dow case denied jurisdiction for state law negligence claim based on federal drug labeling violations
• Federal officer removal cases often involve substantial federal issues in state law claims

Federal Law vs State-Law Claims

Federal Causes of Action

• Automatically satisfy "arising under" requirement for federal question jurisdiction
• Created by federal statutes, constitutional provisions, or federal common law
• Examples include federal civil rights claims (42 U.S.C. § 1983), federal securities law violations, federal antitrust cases
• Federal courts have clear jurisdiction over these cases
• Promote uniform interpretation and application of federal law

State-Law Claims with Embedded Federal Issues

• Require more complex analysis to determine federal question jurisdiction
• Merrell Dow established absence of federal private right of action relevant but not dispositive
• Grable's "importance to the federal system as a whole" test helps determine jurisdiction
• Courts balance federal interest in providing forum against risk of overburdening federal courts
• Examples qualifying for jurisdiction include significant constitutional questions (state property law case involving First Amendment issues)
• Federal statutory interpretation affecting substantial federal interests (state contract dispute involving interpretation of federal telecommunications law)