Ankenbrandt v. Richards Case Brief

Why is the case important?

Petitioner sought to bring a federal tortious action against respondents for the abuse of her children based on diversity-of-citizenship. The district court dismissed the action based on the domestic relations exception to diversity jurisdiction.

Facts of the case


Is there a domestic relations exception to federal jurisdiction, and if such an exception exists, does it permit a district court to abstain from exercising diversity jurisdiction in a tort action for damages?


Federal subject-matter jurisdiction is proper in this case pursuant to Section:1332 because the domestic relations exception encompasses only cases involving the issuance of a divorce, alimony, or child custody decree.
Previous federal precedent disclaimed any jurisdiction upon the subject of divorce, or for the allowance of alimony. Although technically dicta, this formed the basis for excluding domestic relations cases. Because this rule has been recognized for nearly a century and a half, the Court will continue to recognize the limitation.


  • Case Brief: 1992
  • Petitioner: Ankenbrandt, As Next Friend And Mother Of L. R., et al.
  • Respondent: Richards et al.
  • Decided by: Rehnquist Court

Citation: 504 US 689 (1992)
Argued: Mar 31, 1992
Decided: Jun 15, 1992