Opinion

Steel Co. v. Citizens for a Better Environment

  • 523 U.S. 83
  • 11 Fla. L. Weekly Fed. S 369
  • 98 Daily Journal DAR 2102
  • 1998 Colo. J. C.A.R. 1025
  • 66 U.S.L.W. 4174
Court
Supreme Court of the United States
Filed
Mar 4, 1998
Status
Published
Author
Breyer
On the bench
Scalia, Scalía, Rehnquist, O'Connor, Kennedy, Thomas, Breyer, Stevens, Sou-Ter, Ginsburg
Cited by
9,957 cases
Authority
More cited than 11.3%

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.
    District Court, District of ColumbiaJul 7, 2014Read it
  • 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,”
    District Court, District of ColumbiaNov 22, 2010Read it
  • 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,”
    District Court, District of ColumbiaJul 12, 2010Read it
  • 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.
    District Court, District of ColumbiaMar 27, 2002Read it

The opinion

Justice Breyer,

concurring in part and concurring in the judgment,

I agree with the Court that the respondent in this case lacks Article III standing. I further agree that federal courts often, and typically should, decide standing questions at the outset of a case. That order of decision (first jurisdiction then the merits) helps better to restrict the use of the federal courts to those adversarial disputes that Article III defines as the federal judiciary’s business. But my qualifying words “often” and “typically” are important. The Constitution, in my view, does not require us to replace those words with the word “always.” The Constitution does not impose a rigid judicial “order of operations,” when doing so would cause serious practical problems.

This Court has previously made clear that courts may “re-serv[e] difficult questions of . . . jurisdiction when the case alternatively could be resolved on the merits in favor of the same party.” Norton v. Mathews, 427 U. S. 524, 532 (1976). That rule makes theoretical sense, for the difficulty of the jurisdictional question makes reasonable the court’s jurisdictional assumption. And that rule makes enormous practical sense. Whom does it help to have appellate judges spend their time and energy puzzling over the correct answer to an intractable jurisdictional matter, when (assuming an easy answer on the substantive merits) the same party would win or lose regardless? More importantly, to insist upon a rigid “order of operations” in today’s world of federal-court caseloads that have grown enormously over a generation means unnecessary delay and consequent added cost. See L. Mecham, Judicial Business of the United States Courts: 1996 Report of the Director 16,18,23; Report of the Proceedings of the Judicial Conference of the United States *112 106, 115, 143 (1971) (indicating that between 1971 and 1996, annual appellate court caseloads increased from 132 to 311 eases filed per judgeship, and district court caseloads increased from 341 to 490 cases filed per judgeship). It means a more cumbersome system. It thereby increases, to at least a small degree, the risk of the “justice delayed” that means “justice denied.”

For this reason, I would not make the ordinary sequence an absolute requirement. Nor, even though the case before us is ordinary, not exceptional, would I simply reserve judgment about the matter. Ante, at 110-111 (O’Connor, J., concurring). I therefore join only Parts I and IV of the Court’s opinion.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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