Ohio v. Wyandotte Chems. Corp. - 401 U.S. 493, 91 S. Ct. 1005 (1971)

Rule:

Two principles seem primarily to have underlain conferring upon the United States Supreme Court original jurisdiction over cases and controversies between a state and citizens of another state or country. The first is the belief that no state should be compelled to resort to the tribunals of other states for redress, since parochial factors might often lead to the appearance, if not the reality, of partiality to one's own. The second is that a state, needing an alternative forum, of necessity had to resort to the Court in order to obtain a tribunal competent to exercise jurisdiction over the acts of nonresidents of the aggrieved state.

Facts:

The State of Ohio, seeking to invoke the original jurisdiction of the United States Supreme Court over state actions against citizens of other states or countries under Article III of the Federal Constitution, filed a motion for leave to file a bill of complaint for abatement of a nuisance, alleging that the defendants, two out-of-state domestic corporations and a Canadian corporation owned by one of the domestic corporations, were responsible for contaminating Lake Erie by dumping mercury into its tributaries outside of Ohio. The state, suing on behalf of itself and its citizens, sought a decree declaring the introduction of mercury into Lake Erie's tributaries a public nuisance, perpetually enjoining the defendants from such acts, requiring the defendants either to remove the mercury or to pay the costs of such removal, and directing the defendants to pay monetary damages for the harm done to the lake, its fish, wildlife, and vegetation, and the citizens and inhabitants of Ohio.

Issue:

Should the court grant the State of Ohio’s motion for leave to file its complaint?

Answer:

No.

Conclusion:

The United States Supreme Court denied the state's motion for leave to file its complaint, without prejudice to its right to commence other appropriate judicial proceedings. The Court held that (1) although the complaint stated a cause of action within the court's original jurisdiction, nevertheless the court had discretion to decline jurisdiction in order to protect itself from abuse of the opportunity to resort to its original jurisdiction in the enforcement by states of claims against citizens of another state or country, and (2) notwithstanding the public importance of elimination of environmental blight, the court would decline to exercise its original jurisdiction in the case at bar, particularly since the action was based on complex factual issues and did not call for resolution of difficult or important problems of federal law.