By Carson Smith

On February 12, 2015, the Fourth Circuit, in an unpublished opinion, affirmed the District Court of South Carolina’s dismissal in Holmes v. Moore due to lack of subject matter jurisdiction.

Holmes Argued that the Domestic Relations Exception to Subject Matter Jurisdiction Did Not Apply

Holmes brought a breach of contract and promissory estoppel action against her former husband. She brought the case in federal court based on diversity jurisdiction. However, the district court dismissed the case, ruling that Holmes suit fell within the domestic relations exception. This exception has traditionally relieved federal courts from involvement in matters of divorce, child care, and custody.

On appeal, Holmes argued that the domestic relations exception did not apply in this case because the “property settlement agreement that she [sought] to enforce [did] not involve issues related to the divorce decree.” Instead, she argued, the settlement agreement stood alone as an issue of contract law.

Fourth Circuit Found No Reversible Error and Affirmed the District Court’s dismissal

The Fourth Circuit reviewed the issue of law de novo. After reviewing the record, the Fourth Circuit found no reversible error and affirmed the district court’s dismissal based on the domestic relations exception.