--- title: "Strawbridge v. Curtiss" type: Landmark Case source: https://casebriefly.com/landmark-cases/strawbridge-v-curtiss --- # Strawbridge v. Curtiss Strawbridge established the rule of complete diversity for diversity jurisdiction under Article III and 28 U.S.C. Section 1332. The case held that diversity jurisdiction requires that no plaintiff be a citizen of the same state as any defendant, a stricter requirement than minimal diversity. This interpretation has governed diversity jurisdiction for over two centuries. ## Citation 7 U.S. (3 Cranch) 267 (1806) ## Year 1806 ## Court Supreme Court of the United States ## Facts The case involved a dispute among multiple parties — some plaintiffs and some defendants were citizens of the same state (Massachusetts). The specific underlying facts of the dispute have been largely lost to history, but the jurisdictional question was whether a federal court could exercise diversity jurisdiction when there was not complete diversity among all parties. ## Procedural History Chief Justice Marshall delivered a brief opinion dismissing the case for lack of jurisdiction. The case was decided without extensive procedural history being reported. ## Issue Whether federal diversity jurisdiction exists when some plaintiffs and defendants are citizens of the same state, or whether complete diversity among all parties is required. ## Holding Chief Justice Marshall held that diversity jurisdiction requires complete diversity: every plaintiff must be a citizen of a different state from every defendant. Because some parties on both sides shared citizenship in the same state, the federal court lacked jurisdiction. ## Reasoning Chief Justice Marshall interpreted the diversity statute (the predecessor to 28 U.S.C. Section 1332) to require that the controversy be 'between citizens of different states.' He construed this language to mean that complete diversity was required — no plaintiff could be a citizen of the same state as any defendant. Marshall acknowledged that the constitutional grant of diversity jurisdiction in Article III might be broader, but held that the statutory language imposed this more restrictive complete diversity requirement. ## Impact The complete diversity rule has governed federal diversity jurisdiction for over 200 years and remains binding precedent. Congress has enacted narrow exceptions allowing minimal diversity in specific contexts, such as the Class Action Fairness Act (CAFA) and interpleader under 28 U.S.C. Section 1335, but the general rule remains complete diversity. The distinction between constitutional diversity (minimal diversity is sufficient) and statutory diversity (complete diversity required) is a foundational concept in civil procedure. ## Key Quotes - Each distinct interest should be represented by persons, all of whom are entitled to sue, or may be sued, in the federal courts. - The court understands these expressions to mean that each distinct interest should be represented by persons, all of whom are entitled to sue, or may be sued, in the federal courts. ## Related Cases - mas-v-perry - louisville-and-nashville-railroad-v-mottley - erie-railroad-v-tompkins ## Exam Relevance Strawbridge is tested on every civil procedure exam covering subject matter jurisdiction. Students must understand the complete diversity rule and be able to identify when diversity is or is not destroyed by the citizenship of the parties. Exam questions often involve multi-party lawsuits where one party's citizenship may defeat diversity. Students should also know the exceptions to complete diversity, such as CAFA and interpleader. ## Study Tips - The rule is simple but critical: every plaintiff must be diverse from every defendant. One overlapping citizenship destroys jurisdiction. - Distinguish constitutional diversity (Article III requires only minimal diversity) from statutory diversity (Section 1332 requires complete diversity as interpreted in Strawbridge). - Know the major exceptions: CAFA (minimal diversity for class actions over $5 million), statutory interpleader (minimal diversity under Section 1335), and supplemental jurisdiction (Section 1367). - Practice applying the rule to multi-party scenarios, including cases involving joinder, intervention, and third-party claims. ## Doctrine Established Complete Diversity Rule --- Source: [Strawbridge v. Curtiss — CaseBriefly](https://casebriefly.com/landmark-cases/strawbridge-v-curtiss)