3.3 Supplemental Jurisdiction
3 min read•august 16, 2024
allows federal courts to hear without independent federal jurisdiction. This power, codified in , promotes efficiency by consolidating disputes and avoiding .
The "" test determines if claims are part of the same case. Courts can decline supplemental jurisdiction for factors like novel state law issues or when state claims predominate over federal ones.
Supplemental Jurisdiction: Purpose and Scope
Defining Supplemental Jurisdiction
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- Supplemental jurisdiction allows federal courts to hear additional claims closely related to the original claim with subject matter jurisdiction
- Encompasses both (additional claims by plaintiff) and (claims by other parties)
- Enables federal courts to hear state law claims lacking independent basis for federal jurisdiction
- Promotes by consolidating related claims in one forum
- Helps avoid piecemeal litigation and promotes efficient dispute resolution
Benefits and Applications
- Allows adjudication of related claims in a single proceeding (multiple tort claims arising from one accident)
- Expands federal court authority to resolve entire legal disputes (contract claim and related fraud allegation)
- Reduces litigation costs for parties by avoiding multiple proceedings
- Prevents inconsistent judgments on related issues (liability determinations)
- Improves overall efficiency of the judicial system by reducing case backlog
Statutory Basis for Supplemental Jurisdiction
28 U.S.C. § 1367: Core Provisions
- Codifies supplemental jurisdiction doctrine providing statutory framework for federal courts
- Subsection (a) grants supplemental jurisdiction over claims part of same case or controversy
- Extends to claims involving joinder or intervention of additional parties with exceptions
- Subsection (b) limits supplemental jurisdiction in diversity cases preventing circumvention of complete diversity
- Addresses statute of limitations for state law claims providing 30-day grace period for refiling in state court
Limitations and Exceptions
- Restricts supplemental jurisdiction in certain diversity cases (claims by plaintiffs against non-diverse third parties)
- Preserves complete diversity requirement in cases based solely on 28 U.S.C. § 1332
- Excludes claims by plaintiffs against persons made parties under Rules 14, 19, 20, or 24 of the Federal Rules of Civil Procedure
- Maintains jurisdictional restrictions for claims by persons proposed to be joined as plaintiffs under Rule 19 or intervening under Rule 24
Same Case or Controversy: Defining the Limits
Common Nucleus of Operative Fact Test
- Established in (1966) to determine same case or controversy
- Requires federal and state claims share substantial factual overlap
- Claims should ordinarily be tried together in one judicial proceeding
- Fact-specific inquiry analyzing relationship between claims
- Considers similarity of witnesses, evidence, and legal theories between federal and state claims
Distinguishing Related and Unrelated Claims
- Claims arising from entirely separate facts or distinct legal issues generally not part of same case or controversy
- Related claims examples include multiple injuries from single car accident or breach of contract and related fraud
- Unrelated claims examples include unconnected tort claim and patent infringement allegation
- Constitutional requirement under Article III satisfied by claims meeting common nucleus test
- Courts analyze factual and legal connections between claims to determine supplemental jurisdiction applicability
Declining Supplemental Jurisdiction: Factors and Considerations
Discretionary Factors under § 1367(c)
- Novel or complex issue of state law promotes federalism by deferring to state courts (interpretation of new state statute)
- State law claim substantially predominates over original jurisdiction claim(s) (major state law class action with minor federal claim)
- Dismissal of all original jurisdiction claims (remaining state law claims after summary judgment on federal claims)
- Exceptional circumstances with compelling reasons for declining jurisdiction (parallel state court proceedings nearing completion)
Balancing Considerations
- Courts weigh factors against principles of judicial economy, convenience, fairness, and comity
- Judicial economy considers efficient use of court resources (avoiding duplicative proceedings)
- Convenience factors include geographic location of evidence and witnesses
- Fairness evaluates potential prejudice to parties (statute of limitations concerns)
- Comity respects state court expertise in state law matters
- Decision to decline supplemental jurisdiction discretionary and reviewed for abuse of discretion on appeal
Key Terms to Review (19)
28 U.S.C. § 1367: 28 U.S.C. § 1367 is a statute that provides federal courts with supplemental jurisdiction over additional claims that are related to a case already under their jurisdiction. This means that if a federal court has original jurisdiction, it can also hear related state law claims, even if those claims would not independently qualify for federal jurisdiction. This provision is crucial for allowing more comprehensive handling of cases and promoting judicial efficiency by preventing the need for separate state court litigation.
Anchor Claim: An anchor claim is a primary legal claim that provides the foundation for a case, allowing the court to exercise jurisdiction over related claims that might not independently qualify for jurisdiction. This concept is crucial when dealing with supplemental jurisdiction, as it helps courts to manage cases involving multiple claims effectively and ensures a comprehensive resolution of disputes in a single judicial proceeding.
Ancillary Jurisdiction: Ancillary jurisdiction refers to the ability of a federal court to hear additional claims that are related to a case already before it, even if those claims would not independently qualify for federal jurisdiction. This concept allows for the efficient resolution of related disputes in a single forum, thereby promoting judicial economy and reducing the risk of inconsistent judgments.
Common nucleus of operative fact: A common nucleus of operative fact refers to a set of facts that are central to multiple legal claims or actions, allowing them to be linked together in a single lawsuit. This concept is crucial for establishing supplemental jurisdiction, as it helps determine whether a federal court can hear claims that do not independently qualify for federal jurisdiction but are related to claims that do.
Compulsory Joinder: Compulsory joinder is a procedural requirement that mandates certain parties to be included in a lawsuit if their absence would prevent the court from granting complete relief or would impair the ability of existing parties to protect their interests. This concept is crucial in ensuring that all parties with a significant interest in the litigation are present, thus preventing multiple lawsuits and inconsistent judgments.
Discretionary Dismissal: Discretionary dismissal refers to a court's authority to dismiss a case based on the judge's judgment, often due to procedural issues or lack of merit. This power allows judges to manage their dockets effectively and ensure that only cases meeting certain legal standards proceed in the judicial system. The concept ties closely to supplemental jurisdiction as courts may dismiss state law claims that are not sufficiently related to the federal claims being adjudicated.
Diversity Jurisdiction: Diversity jurisdiction is a form of subject matter jurisdiction that allows federal courts to hear cases where the parties are from different states or countries and the amount in controversy exceeds $75,000. This type of jurisdiction is designed to provide a neutral forum for parties who may not receive an unbiased trial in their own state courts.
Federal Question Jurisdiction: Federal question jurisdiction refers to the authority of federal courts to hear cases that arise under the Constitution, federal laws, or treaties. This jurisdiction ensures that federal courts can resolve issues involving federal statutes and constitutional questions, providing a uniform interpretation and application of the law across all states.
Judicial Economy: Judicial economy refers to the principle of minimizing waste of judicial resources and promoting efficiency in the legal process. It aims to streamline proceedings, reduce unnecessary litigation, and encourage resolution of disputes in a way that conserves court time and resources. This concept underpins various procedural rules and doctrines that facilitate quicker and more cost-effective dispute resolution.
Kokkonen v. Guardian Life Insurance Co.: Kokkonen v. Guardian Life Insurance Co. is a significant U.S. Supreme Court case that established principles regarding supplemental jurisdiction, specifically clarifying the limits on a federal court's ability to hear state law claims related to federal claims. The ruling emphasized that supplemental jurisdiction can only be exercised when there is an independent basis for federal jurisdiction and a sufficient connection between the claims.
Pendent jurisdiction: Pendent jurisdiction is a legal doctrine allowing federal courts to hear state law claims that are closely related to federal law claims within the same case. This concept arises when a federal court has original jurisdiction over one claim, typically a federal question, and thus can assert jurisdiction over additional claims that share a common nucleus of operative fact with the original claim, even if those additional claims would not independently qualify for federal jurisdiction.
Permissive Joinder: Permissive joinder is a legal concept that allows multiple parties to join together in a single lawsuit, as long as the claims arise out of the same transaction or occurrence, or share common questions of law or fact. This process promotes judicial efficiency and can streamline cases by addressing related issues in one proceeding, thereby reducing the number of separate lawsuits that would otherwise be necessary.
Piecemeal litigation: Piecemeal litigation refers to the process of addressing legal disputes in separate, fragmented parts instead of resolving all related issues in a single comprehensive action. This often leads to multiple lawsuits concerning the same underlying issues, resulting in inconsistent outcomes and increased legal costs. Such an approach can disrupt judicial efficiency and lead to conflicting judgments across different courts.
Related Claims: Related claims refer to legal issues or causes of action that arise from a common set of facts or circumstances, allowing them to be adjudicated together in a single judicial proceeding. This concept is crucial for managing judicial efficiency and preventing inconsistent rulings, especially when it comes to the application of supplemental jurisdiction. By allowing claims that are related to an original jurisdictional claim to be heard together, courts can streamline the litigation process and provide comprehensive resolutions.
Rule 18 - Joinder of Claims: Rule 18 allows a party in a lawsuit to join multiple claims against an opposing party in one action. This means that a plaintiff can bring all related claims in a single lawsuit, promoting efficiency and reducing the chances of inconsistent judgments across separate cases. This rule plays a crucial role in the judicial process, encouraging parties to address all their grievances together rather than in fragmented lawsuits.
Rule 20 - Permissive Joinder of Parties: Rule 20 allows multiple parties to join or be joined in a single action if they assert claims that arise out of the same transaction or occurrence and if there is a common question of law or fact. This rule promotes judicial efficiency by allowing related claims to be resolved together, preventing fragmented litigation and conserving judicial resources.
Supplemental Claim: A supplemental claim is a legal claim that is added to an existing lawsuit, allowing a party to bring in additional issues or parties related to the original claim. This helps streamline litigation by enabling the court to resolve all related matters in one proceeding, thus conserving resources and avoiding multiple lawsuits. Supplemental claims are typically governed by rules that define their scope and requirements, ensuring they connect to the main action sufficiently.
Supplemental jurisdiction: Supplemental jurisdiction allows federal courts to hear additional claims that are related to the original claims being brought before them, even if those additional claims do not independently meet the requirements for federal jurisdiction. This mechanism ensures that cases can be resolved efficiently in one judicial forum, rather than splitting them up between different courts and systems, which could lead to inconsistent results.
United Mine Workers v. Gibbs: United Mine Workers v. Gibbs is a significant case concerning supplemental jurisdiction, where the Supreme Court ruled on the ability of federal courts to hear state law claims that are closely related to federal law claims being brought before them. This case is important because it clarified the conditions under which federal courts can exercise supplemental jurisdiction over state law claims, emphasizing the need for a common nucleus of operative fact between federal and state claims.