Supplemental Jurisdiction Flashcards
What is the purpose of supplemental jurisdiction?
To promote judicial economy and convenience by allowing related claims to be heard in one court rather than multiple courts.
To ensure fairness to the parties, since they will not have to litigate the same issues in multiple forums.
What case originated the concept of supplemental jurisdiction?
The concept originated in the Supreme Court’s decision in United Mine Workers v. Gibbs (1966).
What did the Court hold in United Mine Workers v. Gibbs?
The Court held that a federal court could exercise ‘pendent jurisdiction’ over a state law claim if it was sufficiently related to a federal claim in the same case.
What is the two-part test for constitutional authority established in Gibbs?
- Substantial Federal Claim: The federal claim must be substantial enough to confer federal subject matter jurisdiction.
- Common Nucleus of Operative Facts: Both the federal and state law claims must arise from the same common nucleus of operative facts.
What is the main statute governing supplemental jurisdiction?
The main statute is 28 U.S.C. § 1367.
What does 28 U.S.C. § 1367 subsection (a) state?
It grants federal courts supplemental jurisdiction over all claims that are sufficiently related to claims within the court’s original jurisdiction.
What exceptions does 28 U.S.C. § 1367 subsection (b) provide?
It carves out exceptions to the broad grant of supplemental jurisdiction in cases based solely on diversity jurisdiction.
What does 28 U.S.C. § 1367 subsection (c) allow?
It allows federal courts to decline to exercise supplemental jurisdiction in certain circumstances.
What are some circumstances under which federal courts may decline supplemental jurisdiction?
- If the state law claim raises a novel or complex issue of state law.
- If the state law claim substantially predominates over the federal claim.
- If the court has dismissed all claims over which it has original jurisdiction.
- In exceptional circumstances where compelling reasons exist to decline jurisdiction.
What is the key case that highlights the requirement for statutory authority in supplemental jurisdiction?
Owen Equipment & Erection Co. v. Kroger (1978).
What did the Court find in Owen Equipment & Erection Co. v. Kroger?
The Court held that although there may be constitutional power to hear a related state law claim, the court must also have statutory authority.
What did Exxon Mobil Corp v. Allapattah Servs., Inc. (2005) clarify?
It established an exception allowing multiple plaintiffs to access federal court under supplemental jurisdiction, even if some individual claims fall short of the jurisdictional amount, as long as one plaintiff’s claim meets the requirement.
What factors do federal courts consider when deciding whether to exercise supplemental jurisdiction?
- Judicial economy: Can the case be resolved more efficiently in one court?
- Convenience: Will it be easier for the parties to litigate in one forum?
- Fairness: Will the parties be treated fairly if the case is heard in federal court?
- Jury confusion: Is there a risk that the jury will be confused by the different legal issues involved in the case?
- Novel or complex issues of state law: Is the state law claim so complex that it would be better resolved in state court?
What is the conclusion regarding supplemental jurisdiction?
Supplemental jurisdiction plays a crucial role in allowing federal courts to efficiently and fairly resolve cases that involve both federal and state law claims.
