Edwards v. Bates County

163 U.S. 269 · Supreme Court of the United States · 1896

Facts

A plaintiff sued on two one-thousand-dollar bonds and their attached interest coupons. The Circuit Court dismissed the case for lack of jurisdiction, having excluded the amount of the matured coupons from the calculation of the jurisdictional amount, treating them as 'interest' under the statute.

Procedural history

The case originated in the Circuit Court, where the action was dismissed for want of jurisdiction. The lower court had excluded the value of the interest coupons from the jurisdictional calculation. The plaintiff in error appealed this decision to the Supreme Court. This court reversed the judgment and remanded the cause with directions to set aside the dismissal order and proceed further.

Issue

Should matured interest coupons attached to bonds be considered as 'interest' and excluded from the jurisdictional amount calculation, or as independent principal obligations, for purposes of federal diversity jurisdiction?

Holding

The Supreme Court reversed the lower court's dismissal, holding that the matured interest coupons should be treated as independent, principal demands and included in the jurisdictional amount calculation. This inclusion brought the total amount in dispute within the Circuit Court's jurisdiction.

Rule

Matured interest coupons on negotiable bonds are considered separate, independent contractual obligations, distinct from the principal bond, and are not merely 'interest' for the purpose of calculating the amount in controversy for federal court jurisdiction. They give rise to a separate cause of action.

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Case brief last reviewed 2026-06-05. Prepared by CaseReader from the published opinion.