Civil Procedure: Grable Substantial Federal Issue Test
The Grable Test carves out a “special and small category” of cases from state court jurisdiction arising from state-law claims. The Grable Test serves to determine whether federal question jurisdiction exists when there is a federal issue claimed to be embedded within a state law claim. Grable & Sons Metal Prods. v. Darue Eng’g & Mfg., 545 U.S. 308 (2005).
In determining whether a case warrants federal jurisdiction, courts will evaluate whether the plaintiffs’ state-law claims “necessarily raise a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities,” keeping in mind that the Supreme Court has explained that “Grable exemplifies” a “slim category” of cases.
The Grable Test outlines the following three issues that courts will examine to determine whether a federal court has jurisdiction to hear a claim under §1331:
- If the state-law claim necessarily raises a stated federal issue
- If the federal issue is actually disputed and is substantial
- If the federal court may entertain the claim without distubring any congressionally approved balance between federal and state responsibilities
In sum, federal question jurisdiction is favored when a federal forum will bring “experience, solicitude and hope of uniformity” to a federal issue. Federal question jurisdiction will not be favored if the recognition of a federal issue within a state law will open a flood-gate of litigation into federal courts.
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