Joinder and Supplemental Jurisdiction - Constitutional and Statutory Basis for Supplemental Jurisdiction Flashcards
Article III, Section 2 of the Constitution
Federal courts have the power to hear all cases that arise under the Constitution, laws and treaties of the United States.
United Mine Workers of America v. Gibbs
Supplemental Jurisdiction
A federal court can have supplemental jurisdiction over state and federal claims if the federal and state claims are the type that would be expected to be heard at a single hearing and are derived from a common nucleus of operative fact.
Once a federal court decides whether it has the power to hear a case, it then must decide whether it will
United Mine Workers of America v. Gibbs
Supplemental Jurisdiction Factors
Factors Courts Use When Deciding to Hear a State Claim
- Whether the federal claim gets resolved early
- Whether the state claim is predominant
- Whether the state claim is novel or complex
- Whether trying the federal and state claims together would confuse the jury
Owen Equipment and Erection Company v. Kroger
Diversity
If federal jurisdiction is based on diversity, a court may not have jurisdiction over a plaintiff’s claim against a third-party defendant if there’s no independent basis for federal jurisdiction over that claim.
Claim Preclusion Overridden
If a court decides a claim cannot be joined in a federal court action, the party is not barred from asserting the claim again in state court.
Section 1367(a)
Supplemental Jurisdiction
If a district court has original jurisdiction over a civil case and all the claims are so related that they form part of the same case, the court has supplemental jurisdiction over all the claims. This includes claims that involve the joinder or intervention of additional parties.
Section 1367(b)
Supplemental Jurisdiction - Diversity
If a district court has jurisdiction solely based on diversity, it cannot have supplemental jurisdiction over claims made by the original plaintiffs if the claims would violate § 1332.
Section 1367(c)
Supplemental Jurisdiction - Factors for Denial
A district court may decide to deny supplemental jurisdiction if
- The claim arises under novel or complex state law
- The state claim predominates over the federal claim
- The district court has dispensed with all the federal claims
- There are other compelling reasons to deny supplemental jurisdiction
Section 1367(d)
Supplemental Jurisdiction - Tolling
If a district court denies supplemental jurisdiction over a state claim and the claim is subject to a statute of limitations, the statute of limitations is tolled for 30 days after it is dismissed.