Keith v. Louisiana Department of Education
553 F. Supp. 295 · District Court, M.D. Louisiana · 1982
Facts
Plaintiffs, including state legislators and various educational stakeholders, filed suit seeking a declaratory judgment that the Louisiana Balanced Treatment Act, which mandates teaching creation-science alongside evolution-science, is constitutional. Defendants, including the Orleans Parish School Board, moved to dismiss for lack of subject matter jurisdiction, arguing the Act is unconstitutional. The dispute arose because defendants refused to implement the Act, prompting plaintiffs to seek federal court validation of the state law.
Issue
Does a federal court have subject matter jurisdiction under 28 U.S.C. § 1331 (federal question) or 28 U.S.C. § 1332 (diversity) to entertain a suit seeking a declaratory judgment that a state law is constitutional, when the federal question arises only as an anticipated defense to the state law's enforcement?
Holding
The Court held that it lacked subject matter jurisdiction under both 28 U.S.C. § 1331 and 28 U.S.C. § 1332. Consequently, the plaintiffs' suit was dismissed with prejudice.
Rule
Federal question jurisdiction requires that a right or immunity created by federal law be an essential element of the plaintiff's well-pleaded complaint, not merely an anticipated defense. The Declaratory Judgment Act does not expand federal court jurisdiction, meaning an independent basis for jurisdiction must exist, and the 'reverse role' doctrine does not apply if the declaratory defendant could not have brought a coercive federal action against the declaratory plaintiff.
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