Supplemental jurisdiction refers to the ability for a party to add a state law claim in addition to a federal claim in federal courts. However, this rule is quite limited. The cases below expound on when and how it can be applied.
United Mine Workers v. Gibbs
383 U.S. 715 (1966).
Question
Can a state law claim be heard in federal courts when the parties are not diverse if it is attached to a federal claim? If so, under what circumstances?
Rule
When a plaintiff makes a federal claim, they can attach state claims if it one where the claim would ordinarily be expected to be resolved together. However, just because a claim can be heard, doesn’t mean it can. There are several factors that federal courts can use to their discretion to see if they want to dismiss the state claim.
Holding
The trial court was not wrong to hear the state claim. Reversed for other reasons.
Facts
Plaintiff is a superintendent of a mine in Tennessee. He is suing the United Mine Workers union in Tennessee. When workers from the union were fired from the closing of a mine, this superintendent was assigned to open a new mine with workers from a different union. The members of this union were furious, believing that they should have gotten their jobs back for the new opening. They prevented the opening of the mine and prevented the superintendent from fulfilling his contract. Thus, the superintendent was fired, and he lost several other jobs.
He sued the Union for violating federal law (should have taken your issues with the owner of the mine, not with me), and a state claim for interference with his contract.
The case was tried and a verdict awarded for the plaintiff in federal district court. The trial judge then dismissed the federal claim and the state claim.
Analysis
The judge was not wrong to hear the state claim in the federal court. The reason why a federal judge can hear state claims attached to a federal claim (as a single case) is to take into account “considerations of judicial economy, convenience, and fairness to litigants.” In other words, it would seem a little extreme to dismiss state claims that are tied to a federal claim because then plaintiffs would always try and resolve federal issues in state courts.
However, judges still have discretion to determine whether they will hear a case. For example:
- If a federal claim drops out early, it might make sense to dismiss the state claim so it can be heard in a state court.
- If the state issues predominate the federal claim, it would make sense to hear it in a state court.
- The federal courts are to intrepret state law, so if a state law is unclear, it would make sense for a state court to determine what the law is.
- Hearing state cases in state courts and federal claims in federal courts could lead to less jury confusion.
There may be other reasons, but these are the ones listed in the opinion.
Takeaway
Pretty much the opposite of the Mottley rule
Additional Notes
There is still a way to make it into a federal court when either 1331 or 1332 is lacking from a claim. If the claim is related to another claim that does meet either 1331 or 1332 requirements, then the claim can make it into federal court under 1367. In other words, these claims are anchored to 1331 or 1332.
Related means that the claim comes from the same facts that allowed the other claim to be successful.
These supplemental claims are all state law claims but are lacking either complete diversity or amount in controversy under 1332.
This case
This case was the first case that introduced supplemental jurisdiction.
The court says that this is permitted by the Constitution because the Constitution talks about “cases”, not claims. So, multiple claims can build a case. If there is a 1331 or 1332 claim, another claim lacking can be supplemented because it is part of a case. Case is more broad than claim.
So, how do we know if a claim is part of a related case? The test outlined by Brennen is that the state and federal claims must derive from a common nucleus of operative fact.
§1367(b) only applies to plaintiffs based in diversity jurisdiction. All it is saying is that supplemental jurisdiction in not allowed to override complete diversity. It does not say anything about the amount of controversy, so focus on diversity on exams. A defendant can use the plaintiff’s claims as an anchor for counterclaims, regardless of the diversity.
1367(c) allows district judges to dismiss supplemental claims (can dismiss state claims, not 1331 or 1332 cases) that meet 1367(a).
Szendrey-Ramos v. First Bancorp
512 F. Supp. 2d 81 (Puerto Rico 2007).
Szendrey-Ramos is the plaintiff along with her husband. They filed suits against several corporate officials as well as the corporation.
Question
Can the state law claims be pended onto the federal claim? Which claims should be heard by a federal court?
Rule
§1367 allows state law claims to be added to a federal claim as long as they come from the same nucleus of a case. However, the federal courts have the discretion to disallow the claims if they fall under one of the categories outlined in 1367(c)
- Complex state law
- State law claims predominate over federal claims
- District court dismisses all federal claims
- Other compelling reasons to deny jurisdiction
Holding
State law claims dismissed. Federal claim dismissed against individuals. Motion to dismiss another federal claim against corporation fails.
Facts
The plaintiff was the former general counsel for the defendant. After being alerted of several potential ethic issues with the company, she conducted an investigation into the issues. She presented those findings to the company and outside counsel. Other investigations continued which resulted in the plaintiff losing her job. She was offered no severance package while others were. Also, when the SEC started conducting an investigation, the company blamed the issues on the plaintiff. The plaintiff was not provided an opportunity to defend herself.
She filed several state law claims (3) and one federal claim (against both the individuals and the corporation). The federal claim was a Title VII claim for gender discrimination and retaliation. The state claims were for defamation, wrongful discharge, and violations of the Puerto Rico Constitution.
Analysis
The state law claims are to be dismissed because of rule 1367(c)(1-2). The predominant claims are the state claims. They are separate and distinct from the federal claims and thus should be litigated in a state court. Additionally, the state law claims deal with complex state issues that would be best resolved in a state court. Therefore, these cases should be dismissed without prejudice so they can be refile there.
As for the federal claims, Title VII does not allow for a plaintiff to sue individuals. Therefore, that claim is dismissed but the Title VII claim against the corporation can still be heard in the federal court.
Takeaway
Although state law claims can be pended onto the federal claim, it is rare for a district court to use their discretion to allow that to happen.
Additional Notes
This case relates solely to §1367(c) which allows the the court to dismiss a case. This case is simply an example of that application. It is important to note that a court can only dismiss supplemental claims, not diversity claims. I was on call and did not take any further notes on this subject.
A defendant with a counterclaim that doesn’t meet the requirements for 1332, will be allowed to bring the claim under 1367.
Disclaimer
The content contained in this article may contain inaccuracies and is not intended to reflect the opinions, views, beliefs, or practices of any academic professor or publication. Instead, this content is a reflection on the author’s understanding of the law and legal practices.
