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Law School Case Brief

Ames v. Kansas - 111 U.S. 449, 4 S. Ct. 437 (1884)


U.S. Const. art. III, § 1 provides that the judicial power of the United States shall be vested in one Supreme Court, and in such inferior courts as the Congress may from time to time ordain and establish. Section 2 provides that the judicial power shall extend to all cases, in law and equity, arising under this Constitution, the laws of the United States, and treaties made, or which shall be made, under their authority; to all cases affecting ambassadors, other public ministers and consuls, to controversies between two or more States; between a State and citizens of another State, and between a State, or the citizens thereof, and foreign States, citizens, or subjects. In all cases affecting ambassadors, other public ministers, and consuls, and those in which a State shall be party, the Supreme Court shall have original jurisdiction. In all the other cases before mentioned, the Supreme Court shall have appellate jurisdiction, both as to law and fact, with such exceptions and under such regulations as the Congress shall make. 


The state of Kansas brought actions against defendant corporations and the directors in the state's courts, challenging a corporate merger. Because there were federal rights involved, the corporations and the directors sought removal of the actions to the federal circuit court. In opposition, the state asserted that the federal court lacked jurisdiction due to the Court's exclusive jurisdiction over suits in which a state was a party as provided in U.S. Const. art. III, § 2. On the state's motion, the circuit court remanded the actions to the Supreme Court of the Kansas. Defendant corporations and the directors sought review.


Did the federal circuit court have jurisdiction over the case?




On review, the United States Supreme Court reversed the order to remand in each case and directed the circuit court to entertain the cases because the original jurisdiction provided in Const. art. III, § 2 did not apply to actions where a state was suing parties who were not other states; thus, such suits could be brought in or removed to the federal circuit courts regardless of the character of the parties.

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