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Subject-matter Jurisdiction

By: Derek Hawkins//September 13, 2021//

Subject-matter Jurisdiction

By: Derek Hawkins//September 13, 2021//

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7th Circuit Court of Appeals

Case Name: Carter Page, et al., v. Democratic National Committee, et al.,

Case No.: 20-2781

Officials: SCUDDER, ST. EVE, and KIRSCH, Circuit Judges.

Focus: Subject-matter Jurisdiction

Carter Page, a former advisor to the Donald J. Trump Presidential Campaign, filed suit against the Democratic National Committee, a subsidiary DNC Services Corporation, the law firm Perkins Coie LLP, and two Perkins Coie partners. Page alleges various acts of defamation based on news stories published in the fall of 2016. Having advanced only violations of state law, and further alleging that no defendant is a citizen of his home state of Oklahoma, Page relies on diversity jurisdiction as his gateway into federal court.

The district court dismissed the case for lack of personal jurisdiction. Upon reviewing Page’s notice of appeal and accompanying docketing statement, we questioned the existence of subject matter jurisdiction on the basis that Perkins Coie (with a few of its U.S. based partners working and living abroad) may not qualify as a proper defendant for purposes of diversity jurisdiction under 28 U.S.C. § 1332. Our concern proved accurate. So, while we have no reason to question the district court’s conclusion on personal jurisdiction, we affirm the dismissal of Page’s complaint for lack of subject matter jurisdiction.

Affirmed
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Derek A Hawkins is Corporate Counsel, at Salesforce.

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