690 F.3d 1127
9th Cir.2012Background
- CIRI, an Alaska Native Regional Corporation formed under ANCSA, sues two shareholders, Rude and Rudolph, who were former CIRI board members.
- Plaintiff asserts two ANCSA claims and two Alaska-law claims arising from petitions to lift alienability restrictions and related shareholder actions in 2009.
- The district court held it had federal-question jurisdiction over ANCSA claims and supplemental jurisdiction over state-law claims, and granted summary judgment to CIRI on all claims.
- Rude and Rudolph petitioned for relief arguing lack of federal-question jurisdiction and contested the merits of the second ANCSA claim.
- The district court later altered its view on the merits of the second ANCSA claim, but final judgment remained, and defendants appealed only the jurisdictional ruling.
- ANCSA restricts stock transfer; lifting restrictions requires amendment to the regional corporation’s articles and may be initiated by a shareholder petition under § 1629c(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal-question jurisdiction exists over ANCSA claims | CIRI's ANCSA claims arise under federal law enacted by ANCSA itself. | Jurisdiction should not depend on embedded state-law aspects; questions are not inherently federal. | Yes; there is federal-question jurisdiction. |
| Whether Alaska law embedded in ANCSA claim creates a federal question | Alaska proxy-law standards govern the petition to lift restrictions, incorporated into ANCSA claim. | Alaska law embedded in a federal claim does not automatically create federal jurisdiction. | Embedded Alaska-law elements do not negate federal-question jurisdiction. |
| Whether ANCSA limits federal-court jurisdiction over ANCSA claims | ANCSA provisions create federal questions and allow federal review of claims. | § 1601(f) restricts jurisdiction over extinguished claims and may foreclose federal jurisdiction. | § 1601(f) does not limit § 1331 jurisdiction for these ANCSA claims. |
Key Cases Cited
- Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mfg., 545 U.S. 308 (2005) (establishes framework for federal-question jurisdiction in Grable-type cases)
- Empire Healthchoice Assurance, Inc. v. McVeigh, 547 U.S. 677 (2006) (creation of cause of action basis in federal law for jurisdiction)
- Sea-Land Serv., Inc. v. Lozen Int’l, LLC, 285 F.3d 808 (9th Cir. 2002) (nonfrivolous federal claims suffice for jurisdiction)
- Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998) (nonfrivolous federal claim sustains jurisdiction)
- Cement Masons Health & Welfare Trust Fund for N. Cal. v. Stone, 197 F.3d 1003 (9th Cir. 1999) (nonfrivolous federal claim suffices for jurisdiction)
- Puri v. Gonzales, 464 F.3d 1038 (9th Cir. 2006) (standard for reviewing jurisdictional questions)