Porto Rico Railway, Light & Power Co. v. Mor
Headline: Court limits access to U.S. District Court in Puerto Rico, ruling foreign-born residents domiciled on the island cannot use the $3,000 federal diversity rule, so such disputes stay in local insular courts.
Holding:
- Prevents foreign-born Puerto Rico residents from suing in the U.S. District Court under the $3,000 rule.
- Makes such disputes remain in insular courts that use Spanish and civil-law procedures.
- Avoids unequal treatment between American and foreign residents domiciled in Puerto Rico.
Summary
Background
Mor, a Spanish subject who lived (was domiciled) in Porto Rico, sued the Porto Rico Railway, Light and Power Company, a Porto Rico corporation, in the U.S. District Court for Porto Rico for more than $3,000. The District Court allowed the case to proceed despite an objection that it lacked power to hear the suit. The Circuit Court of Appeals asked the Supreme Court to decide whether the District Court really had jurisdiction under §41 of the Jones Act, which gives the District Court jurisdiction in cases where parties are "not domiciled in Porto Rico" and the amount in dispute exceeds $3,000.
Reasoning
The key question was whether the phrase "not domiciled in Porto Rico" applies to noncitizens as well as to American citizens. The Court read the language to apply to the whole list of covered persons. It noted the act’s clear intent to limit the District Court’s reach and relied on practical considerations: treating foreigners who live on the island differently from Americans who live there would impose unfair burdens and conflict with treaty protections that had allowed Spaniards to appear in the island’s courts. On that basis the Court answered the certified question in the negative: the restriction applies to aliens, so the District Court lacked jurisdiction over Mor.
Real world impact
As a result, foreign-born residents who live in Porto Rico cannot use the Jones Act $3,000 federal forum simply because they are noncitizens; similar disputes must be handled in the island’s local courts, where procedures and language differ from the U.S. District Court.
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