Steigleder v. McQuesten

Background

A woman sued in federal court while living in Washington, and the defendants were also residents of Washington. The complaint alleged that the parties were citizens of different States, which is a basic requirement for certain federal lawsuits. Defendants moved to dismiss, questioning whether the federal court really had power to hear the case because the plaintiff was residing in Washington when she filed suit.

Reasoning

The Court addressed whether living in a State is the same as being a legal citizen of that State for purposes of federal access. It explained that an allegation of citizenship in the pleadings is enough to make a prima facie case of federal jurisdiction. The Court relied on an 1875 law that lets the trial court dismiss a case at any time if the dispute is not a real controversy or if parties were collusively joined to create jurisdiction. After reviewing the evidence the trial court gathered, the Court agreed the plaintiff had long been a citizen of Massachusetts and her time living in Washington was temporary, so she had not abandoned Massachusetts citizenship.

Real world impact

The decision means a person who temporarily lives in another State can still be treated as a citizen of their home State for federal diversity claims, so federal courts may keep such cases. It also confirms that trial courts may examine evidence and dismiss suits that are insubstantial or collusive to prevent improper use of federal courts.