Great Lakes Gas Transmission v. Essar Steel Minnesota LLC, No. 16-1101 (8th Cir. 2016)
Annotate this CaseGreat Lakes filed suit against ESML for breach of contract. ESML later filed a motion to dismiss based on lack of subject matter jurisdiction, but the district court denied the motion. The case proceeded to trial and judgment was entered for Great Lakes. The court agreed with the district court that the Natural Gas Act (NGA), 15 U.S.C. 717u, does not create an express cause of action under which Great Lakes may sue for breach of contract; the NGA also does not create an implied cause of action where there is no indication of legislative intent to create a federal cause of action displacing traditional state law breach of contract causes of action; and assuming that the district court correctly held that federal issues were “necessarily raised” and “actually disputed,” the court concluded that the federal issues in this case are not “substantial,” and the federal courts cannot exercise federal question jurisdiction “without disturbing any congressionally approved balance of federal and state judicial responsibilities.” Accordingly, the court vacated and remanded with instructions to dismiss for lack of jurisdiction.
Court Description: Gruender, Author, with Murphy and Shepherd, Circuit Judges] Civil case - Natural Gas Act. The Natural Gas Act does not create an express cause of action under which plaintiff could sue for recovery of payments due under a federal tariff; nor does the Act create an implied cause of action as there is no indication in the Act that Congress intended to create a federal cause of action displacing traditional state law breach of contract causes of action; the district court erred in asserting jurisdiction over the claims because even if federal issues were "necessarily raised" and "actually disputed," the federal issues were not substantial, and a federal court could not exercise federal question without disturbing the congressionally approved balance of federal and state judicial responsibilities; judgment of the district court is vacated and the case is remanded with directions to dismiss the case for lack of jurisdiction.
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