Bell v. Hood

327 U.S. 678 (1946)

 

RULE:

The failure to state a proper cause of action calls for a judgment on the merits and not for a dismissal for want of jurisdiction. Whether the complaint states a cause of action on which relief could be granted is a question of law and must be decided after the court has assumed jurisdiction over the controversy. If the court does later exercise its jurisdiction to determine that the allegations in the complaint do not state a ground for relief, then dismissal of the case would be on the merits, not for want of jurisdiction.

FACTS:

Petitioners allege that Federal Bureau of Investigation agents wrongfully detained them and conducted an unreasonable search and seizure, violating their Fourth and Fifth Amendment rights. Respondents contend that the Fourth and Fifth Amendment do not provide for monetary damages if violated, therefore the case was improperly submitted to the federal civil courts. The trial court dismissed for lack of subject matter jurisdiction, as it did not arise under the Constitution or laws of the United States, as required by 28 U. S. C. § 41(1). The appellate court affirmed, and the US Supreme Court reversed the decision.

ISSUE:

Do federal courts have jurisdiction over cases in which the main issue involves the violation of constitutionally provided rights, even if there is not an established remedy if that right is violated?

ANSWER:

Yes.

CONCLUSION:

Where legal rights have been invaded and a federal statute provides for a general right to sue for such invasion, federal courts may use any available remedy to right the wrong done. Whether the petitioners are entitled to recover depends upon an interpretation of 28 U. S. C. § 41(1) and on a determination of the scope of the Fourth and Fifth Amendments' protection from unreasonable searches and deprivations of liberty without due process of law. The federal courts have jurisdiction to decide on the merits of such federal issues.

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