May 4, 2011
Yesterday, the Seventh Circuit found that both the district court and the parties improperly framed an issue as one of subject matter jurisdiction in
Adkins v. VIM Recycling, Inc., ___ F.3d ___ (7th Cir. 2011), Cause No. 10-2237. In this decision, Judge Hamilton provides a lengthy discussion of just what subject matter jurisdiction is.
less..
This case arose out of a series of environmental suits. IDEM found that VIM was violating environmental regulations and filed two suits against VIM. Some private citizens filed their own suit against VIM, making claims under the federal Resource Conservation and Recovery Act (RCRA),
42 U.S.C. § 6901 et seq.. Under
§ 6972(b)(1)(B) of the RCRA, a private citizen cannot bring a suit under the RCRA "if the Administrator or State has commenced and is diligently prosecuting a civil or criminal action in a court of the United States or a State to require compliance with such permit, standard, regulation, condition, requirement, prohibition, or order."
According to the Court, both "[t]he parties and the district court treated the statutory
bar issue as a question of subject matter jurisdiction." But this was incorrect. The Court said that the RCRA prohibition on bringing a citizen suit was a "claims processing rule" that did not affect the court's adjudicatory authority.
The distinction is vital. Treating a rule as jurisdictional "alters the normal operation of our adversarial system" in which courts address the claims and arguments. If a rule is genuinely jurisdictional, a federal court has an obligation to raise and decide the issue itself even if the parties do not. A jurisdictional question may be raised at any time, including for the first time on appeal, causing unfairness to the parties and wasting the efforts spent on the litigation to that point. Congress can specify that a particular claims-processing rule is jurisdictional, but it is clear that the Supreme Court is not expanding the category of jurisdictional rules without explicit indications from Congress that it intended such drastic results.
Ultimately, the Court reversed the district court's dismissal of the claim.
The Court's discussion on this issue highlights an area in which we've seen some confusion. There is a difference between a court's subject matter jurisdiction and the court's exercise of its jurisdiction through claims processing rules. This distinction can make a big difference, as Judge Hamilton's discussion points out.
Lessons:
- A court only lacks subject matter jurisdiction over a claim if it does not have adjudicatory authority over that claim.
- Rules governing subject matter jurisdiction are distinct from claims processing rules.
- Courts are generally hesitant to say that a rule addresses subject matter jurisdiction if they do not have to do so.
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