The case Hampton v. R.J. Corman Railroad Switching Co. (6th Cir., Case No. 10-5707, June 19, 2012) (PDF), serves as an object lesson in the singular importance of jurisdiction when practicing before federal courts.
Hampton involved a Kentucky plaintiff whose car collided with a train and who subsequently brought common-law tort claims in state court against Defendant R.J. Corman (“RJC”), which owned the train. RJC removed to federal court, and Hampton did not resist removal. The case proceeded to summary judgment, which the district court granted on behalf of RJC. On appeal, however, the Sixth Circuit, in a unanimous opinion by District Judge Gwin of the Northern District of Ohio (sitting by designation), determined sua sponte to resolve a more pressing issue: whether the district court ever had subject matter jurisdiction in the first instance.
Because the parties were not diverse, the panel considered whether federal question jurisdiction existed – and found that it did not. First, the court determined that no federal law created an applicable cause of action, rejecting the argument that the Federal Railroad Safety Act of 1970 (“FRSA”) (49 U.S.C. § 20101 et seq.) conveyed jurisdiction. Next, the court found that Hampton’s state-law tort claims also did not qualify under federal question jurisdiction by implicating significant federal issues. Finally, the court rejected RJC’s argument that jurisdiction should lie under the doctrine of complete preemption, citing the FRSA’s language disclaiming preemption of state-law tort actions.
Concluding, the panel observed that “despite the time, effort, and money that unfortunately have been wasted on litigating this matter, it can proceed no further,” directing the district court to remand the matter to Kentucky state court. Therein lies a valuable lesson for all litigants in federal court.