Supplemental jurisdiction

United States federal civil procedure doctrines
Justiciability
Advisory opinions Standing Ripeness Mootness Political questions Constitutional avoidance
Jurisdiction
Subject-matter Federal question Diversity Amount in controversy Supplemental Removal Class Action Fairness Act of 2005 Personal In personam In rem Quasi in rem
Federalism
Erie doctrine Abstention Anti-Injunction Act Sovereign immunity Abrogation Rooker–Feldman doctrine Adequate and independent state ground
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Supplemental jurisdiction, also sometimes known as ancillary jurisdiction or pendent jurisdiction, is the authority of

Historically there was a distinction between pendent jurisdiction and ancillary jurisdiction. But, under the ruling in Exxon, that distinction is no longer meaningful. Supplemental jurisdiction refers to the various ways a federal court may hear either: state law claims, claims from parties who lack the amount in controversy requirement of diversity jurisdiction, when defendants are joined in claims, or when multiple plaintiffs are joined in claims, like in class action suits.

Definition

By default, courts have supplemental jurisdiction over "all other claims that are so related . . . that they form part of the same case or controversy."^[1] The true test being that the new claim "arises from the same set of operative facts."^[2] This means a federal court hearing a federal claim can also hear substantially related state law claims, thereby encouraging efficiency by only having one trial at the federal level rather than one trial in federal court and another in state court. However, if the case is brought as a diversity action (i.e., the basis for federal jurisdiction is that each defendant comes from a state different from each plaintiff), there generally is no supplemental jurisdiction if such claims would destroy complete diversity. See Exxon Mobil Corp. v. Allapattah Services, Inc. Courts are also free to decline to exercise supplemental jurisdiction in specified or exceptional circumstances (§ 1367(c)).

Pendent jurisdiction

Pendent jurisdiction is the authority of a

Pendent jurisdiction refers to the court's authority to adjudicate claims it could not otherwise hear. The related concept of pendent party jurisdiction by contrast is the court's authority to adjudicate claims against a party not otherwise under the court's jurisdiction because the claim arises from the same nucleus of facts as another claim properly before the court.

The leading case on pendent jurisdiction is United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966). Gibbs has been read to require that (1) there must be a federal claim (whether from the Constitution, federal statute, or treaty) and (2) the non-federal claim arises "from a common nucleus of operative fact" such that a plaintiff "would ordinarily be expected to try them in one judicial proceeding."

The holding in Gibbs has been essentially codified by Congress along with ancillary jurisdiction in 28 U.S.C. § 1367, its supplemental jurisdiction statute. However, Subsection §1367(c)(3) expressly authorizes the district court to dismiss a supplemental claim when the district court has dismissed all claims over which it has original jurisdiction.^[5]

Ancillary jurisdiction

Ancillary jurisdiction is a form of supplemental jurisdiction that allows a

Moore v. New York Cotton Exchange and Owen Equipment & Erection Co. v. Kroger are seminal cases relating to ancillary jurisdiction.

Ancillary jurisdiction has been replaced entirely by supplemental jurisdiction, per 28 U.S.C. § 1367(b), part of the U.S. supplemental jurisdiction statute.

Case law

• Szendrey-Ramos v. First Bancorp (D.P.R. 2007)

References

External links

• 28 U.S.C § 1367 - Supplemental Jurisdiction