holding that a federal court generally may not rule on the merits of a case without first determining that it has jurisdiction, and explaining that failing to make a determination about jurisdiction first “carries the courts beyond the bounds of authorized judicial (10) “Citizenship and Jurisdictional Consideration,” (11) “Arbitration,” and (12) “Trial Requests.” Compl. at 16-37. action and thus offends fundamental principles of separation of powers”
How later courts described this case
- holding that a federal court generally may not rule on the merits of a case without first determining that it has jurisdiction, and explaining that failing to make a determination about jurisdiction first “carries the courts beyond the bounds of authorized judicial (10) “Citizenship and Jurisdictional Consideration,” (11) “Arbitration,” and (12) “Trial Requests.” Compl. at 16-37. action and thus offends fundamental principles of separation of powers”
- holding that environmental group did not have standing in Emergency Planning and Community Right-to-Know Act case because, “although a suitor may derive great comfort and joy from the fact that the United States Treasury is not cheated, that a wrongdoer gets his just deserts, or that the Nation’s laws are faithfully enforced, that psychic satisfaction is not an acceptable Article III remedy because it does not redress a cognizable Article III injury”
- holding that " [d]ismissal for lack of subject- matter jurisdiction because of the inadequacy of the federal claim is proper ... when the claim is 'so insubstantial, implausible, foreclosed by prior decisions . .. or otherwise completely devoid of merit as not to involve a federal controversy'" (second alteration in original) (quoting Oneida Indian Nation ofN.Y. v . Cty. of Oneida, 414 U.S. 661 , 666 (1974))
- stating that it is “established jurisprudence that the failure of a cause of action does not automatically produce a failure of jurisdiction” and quoting Bell v. Hood, 327 U.S. 678, 682, 66 S.Ct. 773, 90 L.Ed. 939 (1946) for the proposition that “ ‘jurisdiction ... is not defeated ... by the possibility that the aver-ments might fail to state a cause of action on which petitioners could actually recover’”
Written by the judges who cited it.
Distinguished
Distinguished by Banner Health v. Sebelius, 55 F. Supp. 3d 1 (2014)
523 U.S. 83, 101, 118 S.Ct. 1003, 140 L.Ed.2d 210 (1998), that doctrine is inapplicable here, where Defendant’s jurisdictional argument is premised on a lack of statutory, rather than constitutional, jurisdiction.
Distinguished by Kursar v. Transportation Security Administration, 751 F. Supp. 2d 154 (2010)
523 U.S. 83, 89, 118 S.Ct. 1003, 140 L.Ed.2d 210 (1998), which is distinguishable from a dismissal for failure to state a claim upon which relief can be granted, which constitutes "a ruling on the merits with res judicata effect,”
Distinguished by Morrow v. United States, 723 F. Supp. 2d 71 (2010)
523 U.S. 83, 89, 118 S.Ct. 1003, 140 L.Ed.2d 210 (1998), which is distinguishable from a dismissal under Federal Rule of Civil Procedure 12(b)(6), which constitutes “a ruling on the merits with res judicata effect,”
Distinguished by Aerovias De Mexico, S.A. De C v. v. National Mediation Board, 211 F. Supp. 2d 1 (2002)
523 U.S. at 88-93, 118 S.Ct. 1003, is inapposite.
The opinion
Justice O’Connor,
with whom Justice Kennedy joins, concurring.
I join the Court’s opinion. I agree that our precedent supports the Court’s holding that respondent lacks Article III standing because its injuries cannot be redressed by a judgment that would, in effect, require only the payment of penalties to the United States Treasury. As the Court notes, ante, at 108, had respondent alleged a continuing or imminent violation of the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA), 42 U. S. C. § 11046 , the requested injunctive relief may well have redressed the asserted injury.
I also agree with the Court’s statement that federal courts should be certain of their jurisdiction before reaching the merits of a case. As the Court acknowledges, however, several of our decisions “have diluted the absolute purity of the rule that Article III jurisdiction is always an antecedent question.” Ante, at 101. The opinion of the Court adequately describes why the assumption of jurisdiction was defensible in those cases, see ante, at 98-100, and why it is not in this case, see ante, at 92-93. I write separately to note that, in my view, the Court’s opinion should not be read as cataloging an exhaustive list of circumstances under which federal courts may exercise judgment in “reserving] difficult questions of . . . jurisdiction when the case alternatively *111 could be resolved on the merits in favor of the same party,” Norton v. Mathews, 427 U. S. 524, 532 (1976).