Jose Ruiz v. The Bradford Exchange, Ltd.

Under the Judiciary Act of 1789, the equity jurisdiction conferred on federal courts is the same as that possessed by the English High Court of Chancery at the nation’s inception. Trump v. CASA, Inc., 606 U.S. 831, 841 (2025). Consistent with equity jurisdiction in the Chancery Court at that time, Section 16 of the Act provides that “suits in equity shall not be sustained” in the federal courts “in any case where plain, adequate and complete remedy may be had at law.” Casting aside this structural limitation on federal judicial authority, the Ninth Circuit held below that defendants can waive the no-adequate-remedy-at-law requirement if they so choose, forcing district courts to adjudicate claims that plainly lack federal equity jurisdiction. If the decision below stands, it would allow a defendant to, among other things, greenlight the issuance of a universal injunction in direct contravention of this Court’s decision in CASA. The question presented is: Can a defendant waive the lack of federal equity jurisdiction where it plainly does not exist, thereby compelling a federal court to exercise equitable powers beyond those conferred by the Judiciary Act of 1789?