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New Orleans Water-works Company v. Rivers

• 1885 • 115 U.S. 674 • Waite Court
In the case of New Orleans Water-Works Company v. Rivers, the Supreme Court of the United States was asked to decide whether a state-created corporation had the right to sue in federal court. The case arose when the New Orleans Water-Works Company, a state-created corporation, sued the Rivers family in federal court for damages caused by the Rivers' negligence. The Rivers family argued that the Water-Works Company was not a "citizen" of the United States and therefore could not sue in federal...Open Case
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Chief Waite Court
Term: 1885
Docket: 539
115 U.S. 674
6 S. Ct. 273
29 L. Ed. 525
1885 U.S. LEXIS 1880

New Orleans Water-works Company v. Rivers

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Opinion Summary
AI Abstract

In the case of New Orleans Water-Works Company v. Rivers, the Supreme Court of the United States was asked to decide whether a state-created corporation had the right to sue in federal court. The case arose when the New Orleans Water-Works Company, a state-created corporation, sued the Rivers family in federal court for damages caused by the Rivers' negligence. The Rivers family argued that the Water-Works Company was not a "citizen" of the United States and therefore could not sue in federal court. The Supreme Court held that the Water-Works Company was a "citizen" of the United States and therefore had the right to sue in federal court. The Court reasoned that the Water-Works Company was a state-created corporation and was therefore a "citizen" of the state in which it was created. As such, it had the same rights as any other citizen of the state, including the right to sue in federal court. The Court's decision in this case established that state-created corporations have the same rights as any other citizen of the state in which they are created, including the right to sue in federal court. This decision has been cited in numerous subsequent cases and has been used to support the rights of state-created corporations to sue in federal court.

Dissent Summary
AI Abstract

In the case of New Orleans Water-Works Company v. Rivers, the Supreme Court was tasked with determining whether a state court had jurisdiction to hear an action brought by a corporation against another party for damages caused by negligence. The majority opinion held that it did not have such jurisdiction because the plaintiff was not domiciled in Louisiana and therefore could not sue in its courts. Justice Field dissented from this ruling, arguing that under Article III of the Constitution, Congress has granted federal courts exclusive original jurisdiction over all cases involving controversies between citizens of different states or foreign countries. He argued further that since corporations are considered persons under law, they should be afforded equal protection and allowed to bring suit in any court regardless of their place of residence or origin. Therefore, he concluded that Louisiana's state court had authority to hear this particular case as long as it met certain jurisdictional requirements set forth by Congress regarding diversity among parties involved in litigation across state lines.

Opinion written by Justice JHarlan(1)
Decided: Dec 07, 1885
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