Subject Matter Jurisdiction- Supplemental Jurisdiction Flashcards
What is supplemental jurisdiction?
When claims that do not invoke diversity of citizenship or FQ get into a federal case because it is substantially related to the original claim that has SMJ.
To get supplemental jurisdiction, you must already….
have a case in federal court. So the case invoked diversity or FQ and is pending in federal court.
Federal courts must have…
SMJ over each claim in the case.
If a counterclaim to a federal claim is a state law claim that is diverse and over the amount in controversy, do you need supplemental jurisdiction?
No, it invokes diversity.
Instead, say the counterclaim by D against P asserted a federal-law claim for $50,000. Would you need supplemental jurisdiction for the counterclaim?
No, it invokes federal question jurisdiction.
Instead, say the counterclaim by D against P asserted a state-law claim for $50,000. Would you need supplemental jurisdiction for the counterclaim?
Yes, it does not invoke diversity or federal question.
What is the test for supplemental jurisdiction?
The claim we want to get into federal court must share a “common nucleus of operative fact” with the claim that invoked federal SMJ (the claim that got the case into federal court).
When is the “common nucleus of operative fact” test always met?
When a claim arises from the same transaction or occurrence as the under- lying case.
P (FL) sues D (GA) on a state-law claim for $250,000. That invokes diversity of citizenship, so the case is in federal court. In that case, D asserts a state-law counterclaim (so it fails FQ) against P for $50,000 (so it fails diversity). The counterclaim arises from a completely separate factual event from P’s claim. Can the counterclaim invoke supplemental jurisdiction?
No, because it arises from a completely separate factual event.
BUT, by statute certain claims cannot invoke supple- mental jurisdiction even though they meet “the test.”
What kind of claim doesn’t apply?
In a diversity case, claims by plaintiffs cannot invoke supplemental jurisdiction.
The limitation applies only in…
diversity cases.
If a claim gets into federal court because of federal question jurisdiction, the limitation on suplemental jurisdiction…
doesn’t apply.
What is the exception to this limitation?
When there are multiple plaintiffs, and the claim by one of them does not meet the amount in controversy requirement (but does involve diversity of citizenship), the plaintiff WILL get supplemental jurisdiction.
What is the summary of supplemental jurisdiction rules?
A non-federal, non-diversity claim can be heard in federal court if it meets “the test” UNLESS it is:
a. Asserted by a plaintiff
b. In a diversity of citizenship (not FQ) case AND
c. It doesn’t involve 2 plaintiffs making separate cases where one plaintiff doesn’t meet AIC requirement.
Even if we meet the requirements for supplemental jurisdiction, the court has discretion to decline it. It can do so if:
- the state law claim is complex, or
- state law issues would predominate in the case, or
- (most likely on the exam) the federal claim was dismissed early in the case.
