The Act of Congress of April 20, 1940, provided that district courts should exercise original jurisdiction over actions "between citizens of different States, or citizens of the District of Columbia, the Territory of Hawaii, or Alaska, and any State or Territory . . . . " The committee report and the title indicate the purpose to extend to citizens of the District of Columbia and the territories the right to sue in federal district courts on grounds solely of diversity of citizenship. Although the committee reports indicated no constitutional difficulties, the majority of the lower federal courts which considered the problem declared the act unconstitutional on the ground that the limitations of Article III prevented the exercise of such jurisdiction.
John D. McLeod S.Ed.,
CONSTITUTIONAL LAW-FEDERAL COURTS-DIVERSITY JURISDICTION- DISTRICT OF COLUMBIA CITIZENS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol48/iss7/7