Ankenbrandt v. Richards
119 L. Ed. 2d 468, 112 S. Ct. 2206 (1992)
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Rule of Law:
The domestic relations exception to federal diversity jurisdiction is a narrow, non-constitutional doctrine that divests federal courts of power only to issue decrees of divorce, alimony, or child custody, and does not bar jurisdiction over tort suits between family members.
Facts:
- Carol Ankenbrandt, a citizen of Missouri, is the mother of two daughters, L. R. and S. R.
- Jon A. Richards, a citizen of Louisiana, is Ankenbrandt's divorced husband and the father of the two daughters.
- Debra Kesler, also a citizen of Louisiana, is Richards' female companion.
- Ankenbrandt alleged that Richards and Kesler committed sexual and physical abuse against her daughters.
- On behalf of her daughters, Ankenbrandt sought monetary damages for the alleged torts committed by Richards and Kesler.
Procedural Posture:
- Carol Ankenbrandt, on behalf of her daughters, sued Jon A. Richards and Debra Kesler in the U.S. District Court for the Eastern District of Louisiana, asserting diversity jurisdiction.
- The respondents filed a motion to dismiss, which the District Court granted, concluding it lacked jurisdiction under the 'domestic relations exception' and, alternatively, that abstention was proper.
- Ankenbrandt (appellant) appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the District Court's decision.
- The U.S. Supreme Court granted Ankenbrandt's petition for a writ of certiorari.
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Issue:
Does the domestic relations exception to federal diversity jurisdiction apply to a tort lawsuit brought in federal court on behalf of children against their former parent and his companion, where the suit does not seek a divorce, alimony, or child custody decree?
Opinions:
Majority - Justice White
No. The domestic relations exception does not bar federal courts from exercising diversity jurisdiction over a tort action for damages. The exception is a narrow, statutory-based doctrine, not a constitutional one, which applies only to cases seeking the issuance of a divorce, alimony, or child custody decree. This historical exception originated in Barber v. Barber and has been implicitly accepted by Congress through its long-standing inaction and subsequent reenactment of the diversity statute. Because this lawsuit is for tort damages and does not ask the federal court to grant a divorce, award alimony, or determine child custody, the exception does not apply and the federal court has proper subject-matter jurisdiction. Furthermore, abstention doctrines are inappropriate here because there is no pending state proceeding (barring Younger abstention) and the case does not involve difficult questions of state policy that would warrant Burford abstention.
Concurring - Justice Blackmun
No. While the federal court has jurisdiction, the majority's creation of a statutory 'exception' is incorrect. The plain text of the diversity statute extends to 'all civil actions' with no mention of domestic relations. The historical practice of federal courts declining to hear these cases is better understood as a matter of discretionary abstention based on comity and state expertise, not a mandatory limit on jurisdiction. The majority's reliance on congressional acquiescence to a strained reading of Barber v. Barber is unpersuasive. Nonetheless, even under an abstention framework, abstention would be inappropriate here because this is a tort claim for damages, which falls outside the core domestic relations matters of divorce, alimony, and custody that justify federal court deference to state courts.
Concurring - Justice Stevens
No. The judgment should be reversed because this case is exceedingly easy and does not fall within any plausible definition of a domestic relations exception. This suit is a tort claim for damages, which is clearly within the jurisdiction of the federal courts. The Court should not have used this straightforward case to decide the difficult and unnecessary broader questions regarding the existence, origin, and scope of the domestic relations exception. It was sufficient to hold that the exception simply does not apply here and remand the case.
Analysis:
This decision significantly clarifies and narrows the scope of the domestic relations exception, a previously murky area of federal jurisdiction. By defining the exception as a narrow, statutory-based rule limited to cases seeking decrees of divorce, alimony, or child custody, the Court provided a clear standard for lower courts. It prevents the dismissal of legitimate tort, contract, and other civil actions from federal court merely because the dispute involves family members. This ruling ensures that victims of torts who meet diversity requirements are not deprived of a federal forum simply because the perpetrator is a relative.
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