Ankenbrandt v. Richards

112 S. Ct. 2206 (1992)

Justice WHITE

Facts:

  • Plaintiff, citizen of Missouri, alleges that defendants, citizens of Louisiana, physically and sexually abused her children (also defendant Richards’ children)

Procedural History:

  • Plaintiff brought action in Louisiana federal district court for seeking monetary damages for physical and sexual abuse of her children
  • District court granted defendants’ motion to dismiss

Reversed and remanded for further proceedings.

Issue:

Whether the domestic relations exception to diversity jurisdiction applies to a case involving alleged torts by the ex-husband and father of plaintiffs and his female companion, or whether the federal courts should abstain from hearing the case.

Holding:

The domestic relations exception to diversity jurisdiction does not apply to a case involving alleged torts by the ex-husband and father of plaintiffs and his female companion, because it does not involve the issuance of a divorce, alimony or child custody decree, and the parties have diverse citizenship. The federal courts should not abstain from hearing the case.

Rule:

The domestic relations exception applies only to cases involving the issuance of a divorce, alimony, and child custody decree.

Rule of Law:

USC § 1332

In Re Burns

Barber v. Barber: “We disclaim altogether any jurisdiction in the courts of the United States upon the subject of divorce, or the allowance of alimony, either as an original proceeding in chancery or as an incidence to divorce a vinculo, or to one from bed and board.” 37.

Judiciary Act of 1789; jurisdiction over all civil actions that exceed the required amount and parties are citizens from different states.

Younger v. Harris

Reasoning:

* The federal courts have adhered to the domestic relations exception since Barber v. Barber (1859), where the court disclaims jurisdiction over cases of divorce and alimony. This nevertheless is dicta relying on older case dicta. Nevertheless, the court in Barber offered no authority or foundation for this limitation. The Barber court did find it had jurisdiction in enforcing the alimony decree.

* The Constitution does not exclude domestic relations from federal jurisdiction.

* The Barber dissenters argued that the exception came from the same exception in chancery courts in England. The majority did not disagree with this reason.

* The exception came to include child custody cases.

* POLICY: (1) Judicial economy- state courts have higher connection with entities that deal with these cases, (2) judicial expertise- state courts have been doing it for 150 years.

* The court has jurisdiction because it is a tort.

Court’s Order:

Reversed and remanded for further proceedings.

Concurring:

Justice BLACKMUN:

Federal courts refusal to hear domestic exception cases is discretionary rather than judicial abstention.

Justices STEVENS & THOMAS:

The case is a torts case, and they do not want to address the issue of the domestic relations exception in this case