After Morty Seinfeld finds out that Uncle Leo was supposed to give Helen $50 from the winnings his father made at the track in 1941, but never did, Morty is determined to get the money Helen is owed. Could Helen sue Uncle Leo in Federal court for the money? Does any Federal court have jurisdiction over the matter? If so, in which Federal court could the suit be brought?
In order for a Federal Court to hear a case, the court must have jurisdiction over the subject matter of the case (“subject matter jurisdiction”), and it must also have personal jurisdiction over the parties involved in the suit (“personal jurisdiction“). Subject matter jurisdiction refers to whether any Federal court can hear the case. Personal jurisdiction refers to whether this particular Federal court can hear the case.
Federal Courts are courts of limited jurisdiction. This means that in order for a Federal court to have subject matter jurisdiction, the controversy must fall into one of a limited number of categories. The two most commonly used categories by Plaintiffs are Federal Question Jurisdiction and Diversity Jurisdiction. Federal Question Jurisdiction is where the claim addresses a question of Federal Law, such as a Constitutional question or a claim grounded in one of the Federal statutes. A simple theft case, such as the one here, is not grounded in Federal law. Instead, it is a matter for State courts to handle. Therefore, Helen will not be able to get her case into Federal court based on Federal Question jurisdiction.
But Helen is not out of luck. Diversity jurisdiction requires that the parties be from different states, and that the amount in controversy be more than $75,000. Here, Helen lives in Florida and Uncle Leo lives in New York, which means that diversity of state citizenship does exist. However, Helen’s claim is only for $50. Even if we adjusted for inflation, as Morty does in the episode, this will still only amount to at most $663.45 at the time of the episode (about $800 in 2019 dollars). Therefore, even though Helen and Uncle Leo are from different states, diversity jurisdiction does not exist and Helen would not be able to sue Uncle Leo in Federal court.
Let’s assume, though, that Helen could meet the amount of controversy requirement. In which Federal court could Helen sue Uncle Leo? This question addresses which court has personal jurisdiction over the parties involved in the suit. One can not just be sued in any Federal court. There has to be some legal reason why this particular Federal court has power over the parties involved in suit. For instance, Helen could not sue Uncle Leo in Federal court in Montana because, simply, neither one of them has anything to do with Montana.
There are 5 ways that a Federal court can have personal jurisdiction over a party. These include: (1) Residency (where a party lives), (2) Consent (if the party consents to the jurisdiction), (3) Service (if a person is served the court paperwork while being physically present in the state), (4) Minimum Contacts (certain legally qualifying contacts with the State), and (5) “at home” jurisdiction (this is for corporations, not relevant here).
In this case, the easiest option would be for Helen to sue Uncle Leo in a New York Federal Court because he lives there and Helen, the other party, would consent to to have the suit heard there.
But what if Helen chose to sue Uncle Leo where she lives, in a Florida Federal Court? Well Uncle Leo doesn’t reside there, and if he’s willing to put Nana in a home to avoid paying the money then it’s pretty likely he wouldn’t be so willing to consent to the Florida Federal Court’s jurisdiction either. If Uncle Leo ever visited Florida then Helen could have the court paperwork served on him directly then, but if Uncle Leo is aware that he will be sued then he could probably just avoid ever going to Florida. This leaves Helen with only the option to show Uncle Leo has certain minimum contacts with the state of Florida, such as doing business in the state, owning property there, or if the suit arose from contacts Uncle Leo had with the state. It doesn’t seem that Uncle Leo has any business or property interests in Florida and and it seems pretty unlikely that Helen could show that there was such sufficient contacts with Florida. The suit has nothing to do with Florida and Uncle Leo does not seem to have any other connection with Florida at all. Therefore, even if the case could be brought in Federal court, it would have to be brought in New York as the Federal Court in Florida has no personal jurisdiction over Uncle Leo
One of the most important threshold questions in any civil suit is: in which court a party can actually file a claim. Bringing a complaint in a court that has no jurisdiction over the matter will only result in the case being thrown out. In this case, Helen’s options are pretty limited, as she will be unable to bring a potential suit against Uncle Leo in a Federal Court. If she really did want to sue him then she would have to do it in a New York State court. So unless Helen wants to fly all the way back to New York to do so, Uncle Leo can feel safe taking Nana out of the home.
That is, unless he’s busted by Buddy!