Law School Case Brief
Grable & Sons Metal Prods. v. Darue Eng'g & Mfg. - 545 U.S. 308, 125 S. Ct. 2363 (2005)
28 U.S.C.S. § 1331's provision for federal-question jurisdiction is invoked by and large by plaintiffs pleading a cause of action created by federal law (e.g., claims under 42 U.S.C.S. § 1983). There is, however, another long-standing, if less frequently encountered, variety of federal "arising under" jurisdiction, judicial precedent having recognized for nearly 100 years that in certain cases federal question jurisdiction will lie over state-law claims that implicate significant federal issues. The doctrine captures the commonsense notion that a federal court ought to be able to hear claims recognized under state law that nonetheless turn on substantial questions of federal law, and thus justify resort to the experience, solicitude, and hope of uniformity that a federal forum offers on federal issues.
The Internal Revenue Service seized real property owned by Grable & Sons Metal Prods. to satisfy a federal tax delinquency and gave Grable notice by certified mail before selling the property to Darue Eng'g & Mfg. Grable subsequently brought a quiet title action in state court, claiming that Darue's title was invalid because 26 U.S.C. § 6335 required the IRS to give Grable notice of the sale by personal service, not certified mail. Darue removed the case to a federal district court as presenting a federal question because the title claim depended on an interpretation of federal tax law. The district court declined to remand the case, finding that it posed a significant federal-law question, and it granted Darue summary judgment on the merits. The United States Court of Appeals for the Sixth Circuit affirmed. The Supreme Court of the United States granted certiorari on the jurisdictional question.
Was a federal cause of action always required to exercise federal-question jurisdiction?
To determine whether federal-question jurisdiction existed over federal issues embedded in state-law claims between non-diverse parties, the question was whether the state-law claim necessarily raised a stated federal issue, actually disputed and substantial, which a federal forum could entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities. The Court held that the instant case warranted federal jurisdiction because Grable's claim was premised on the IRS' failure to give adequate notice as defined by federal law. Thus, whether notice was given within the meaning of 26 U.S.C.S. § 6335(a) was an essential element of the quiet title claim and the meaning of the federal statute was actually in dispute. The statute's meaning belonged in federal court given the government's strong interest in tax collection. Moreover, existing judicial precedent, when read in its entirety, treated the absence of a federal private right of action as evidence relevant to, but not dispositive of, the sensitive judgments about congressional intent that 28 U.S.C.S. § 1331 required. The lower court's judgment, affirming federal jurisdiction over the quiet title action, was affirmed.
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