Columbia Gas Transmission, LLC v. Kanwal Singh
707 F.3d 583
| 6th Cir. | 2013Background
- Columbia Gas Transmission sued Kanwal Singh and Lynn Singh over the scope of an existing gas-pipeline easement near Columbus, Ohio.
- Columbia sought to enjoin the Singhs and their tenant from activities it claimed could violate federal duties under the Natural Gas Act (NGA) and safety regulations.
- The complaint functioned as a state-law interference-with-easement claim with a federal-labeling that argued potential NGA implications.
- The district court held a status conference and believed a settlement had been reached but later granted enforcement of the settlement.
- The district court lacked subject-matter jurisdiction because the action did not assert a federal cause of action or arise under federal law; the court vacated the judgment on that basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal-question jurisdiction exists. | Columbia argues arising-under jurisdiction under NGA and federal-law implications. | Singhs argue no substantial federal question; no federal action; nondiverse state-law dispute. | No federal-question jurisdiction; case is a state-law claim with no substantial federal interest. |
| Whether NGA creates a private right of action or exclusive federal jurisdiction applies. | Columbia relies on NGA §22/717u to claim exclusive federal forum. | Singhs contend NGA does not create a private right of action for this dispute and does not preclude state court jurisdiction. | NGA does not create a private right of action for this claim nor confer arising-under jurisdiction; §717u is not a private-action grant. |
| Whether federal common law or substantial-federal-question jurisdiction applies. | Columbia hints at potential federal-common-law governance of easement scope. | Singhs maintain state-law governs easement scope. | No substantial federal-question jurisdiction; Ohio law governs the scope of undefined easements. |
| Whether the district court’s reliance on NGA jurisdiction was correct or ancillary jurisdiction controls. | Columbia asserted federal jurisdiction to enforce a settlement. | Singhs argue lack of jurisdiction; no ancillary basis given for federal jurisdiction. | No ancillary jurisdiction; jurisdiction does not exist under relevant statutes. |
Key Cases Cited
- Mikulski v. Centerior Energy Corp., 501 F.3d 555 (6th Cir. 2007) (en banc test for substantial federal-question jurisdiction)
- Pan American Petroleum Corp. v. Superior Court of Delaware for New Castle County, 366 U.S. 656 (U.S. 1961) (§ 717u does not create private action beyond arising-under jurisdiction)
- Bell v. Hood, 327 U.S. 678 (Sup. Ct. 1946) (federal courts may exercise jurisdiction where federal-law recovery is sought)
- J.I. Case Co. v. Borak, 377 U.S. 426 (Sup. Ct. 1964) (statutory grants of jurisdiction; creates venue/service, not causes of action)
- Touche Ross & Co. v. Redington, 442 U.S. 560 (Sup. Ct. 1979) (parallel jurisdictional provisions do not create private rights of action)
- Drain v. Columbia Gas Transmission Corp., 191 F.3d 552 (4th Cir. 1999) (state-law title/ownership disputes and NGA considerations)
- Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mfg., 545 U.S. 308 (S. Ct. 2005) (test for substantial federal-question jurisdiction)
- Smith v. Kansas City Title & Trust Co., 255 U.S. 180 (Sup. Ct. 1921) (limits of federal-question jurisdiction; not all federal-interest cases arise under federal law)