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Ankenbrandt v. Richards - 504 U.S. 689, 112 S. Ct. 2206 (1992)

Rule:

The domestic relations exception to federal diversity jurisdiction divests the federal courts of power to issue divorce, alimony, and child custody decrees.

Facts:

Plaintiff Carol Ankenbrandt, a citizen of Missouri, brought this suit on behalf of her daughters in the United States District Court for the Eastern District of Louisiana, alleging federal jurisdiction based on the diversity-of-citizenship provision of 28 U. S. C. § 1332, and seeking monetary damages for alleged torts committed against the girls by defendants, the girls' father and his female companion, who were citizens of Louisiana. The plaintiff asserted that a Louisiana state court had previously entered a judgment terminating the former husband’s parental rights because of the alleged sexual and physical abuse of two daughters  The court granted defendants' motion to dismiss without prejudice, ruling in the alternative that it lacked jurisdiction because the case fell within the "domestic relations" exception to diversity jurisdiction and that its decision to dismiss was justified under the abstention principles announced in Younger v. Harris, 401 U.S. 37, 27 L. Ed. 2d 669, 91 S. Ct. 746, under which a federal court will abstain from interfering with a pending state proceeding, said that abstention was a doctrine designed to promote federal-state comity, and that abstention was required when the rendering of a decision would disrupt the establishment of a coherent state policy. The United States Court of Appeals for the Fifth Circuit affirmed. Plaintiff filed a petition for certiorari review.

Issue:

  1. Did the domestic relations exception to diversity jurisdiction exist?
  2. Did the district court err in dismissing the case for lack of jurisdiction?

Answer:

1) Yes 2) Yes

Conclusion:

The United States Supreme Court concluded that a domestic relations exception existed; however, it only divested the federal courts of power to issue divorce, alimony, and child custody decrees. The domestic relations exception did not divest the federal courts of jurisdiction in cases like the present one which did not involve the issuance of divorce, alimony, or child custody decrees. The Court noted that plaintiff mother was not seeking such a decree; rather, the lawsuit alleged that defendants had committed torts against the children. Thus, the Court held that it was error to dismiss the lawsuit for lack of jurisdiction. Further, it was improper to invoke the Younger abstention when no state proceeding was pending and no assertions of important state interests were made.

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