In the case of RuhrGas AG v. Marathon Oil Company, the Supreme Court ruled that federal courts have discretion to consider issues of subject-matter jurisdiction before addressing personal jurisdiction. The dispute arose when Marathon Oil and others sued RuhrGas in a Texas state court over a natural gas field in Germany. After removing the case to Federal District Court, RuhrGas moved for dismissal on grounds of both lack of personal jurisdiction and failure to state a claim upon which relief can be granted (subject matter). The District Court dismissed for lack of subject-matter jurisdiction without reaching the question about personal jurisdiction or merits. On appeal, however, it was held that unless there is an obvious issue with personal jurisdiction, district courts must confirm their own jurisdictions first before considering other matters such as subject matter or merits - leading to this Supreme Court ruling.

In the dissenting opinion for RUHRGAS AG v. MARATHON OIL COMPANY et al., Justice Stevens argued that federal courts should not dismiss a case on jurisdictional grounds before addressing whether there is an applicable federal question or diversity of citizenship between parties, which would allow them to hear the case in the first place. He contended that this approach was consistent with past Supreme Court rulings and Congressional intent behind relevant statutes. Furthermore, he expressed concern over potential abuse by defendants who might manipulate procedural rules to delay proceedings or avoid unfavorable state courts. Finally, he disagreed with the majority's reliance on efficiency as a justification for their decision because it could lead to unjust results if applied indiscriminately.