Traditional Aggregation Rules and Supplemental Jurisdiction in Federal Courts, Slides of Civil procedure

The traditional rules for aggregation of claims in federal courts, focusing on multiple parties suing the same defendant for different claims, and the supplemental jurisdiction doctrine that expands the subject matter jurisdiction of federal courts to related claims. Hypothetical scenarios, legal cases, and their rationales, as well as the current supplemental jurisdiction statute.

Typology: Slides

2012/2013

Uploaded on 01/26/2013

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TRADITIONAL AGGREGATION
RULES CONT’D
Multiple Ps sue the same D for different claims:
e.g. Dorothy ME (passenger) sues George- TX
(driver) in federal court for $45,000 for damages
suffered in a car crash.
A. Is there subject matter jurisdiction? What if
Laura- DC, also a passenger in George’s car,
wants to join as a plaintiff to sue George for
$35,000 for her injuries arising from the same
accident?
B. Will the supplemental jurisdiction statute
change the result?
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TRADITIONAL AGGREGATION

RULES CONT’D

  • Multiple Ps sue the same D for different claims: e.g. Dorothy – ME (passenger) sues George- TX (driver) in federal court for $45,000 for damages suffered in a car crash.
  • A. Is there subject matter jurisdiction? What if Laura- DC, also a passenger in George’s car, wants to join as a plaintiff to sue George for $35,000 for her injuries arising from the same accident?
  • B. Will the supplemental jurisdiction statute change the result?

TRADITIONAL AGGREGATION

RULES CONT’D

  • Would it make any difference to your

answers in the previous hypothetical if

Dorothy’s claim was for $90,000?

HYPO CONTINUED

  • Barbie and Ken’s lawyer, Dawn, files an action

in federal court, naming High Heels as plaintiff and claiming the amount of the $90,000 debt in damages. Barbie and Ken, as equal partners, each have an interest of $45,000 in the claim. Does the court have subject matter jurisdiction?

TRADITIONAL RULES FOR

AGGREGATION

  • Single P w/2 or more claims vs. single D
  • 2 Ps with claims against a single D -

“separate and distinct”/”common &

undivided interest” test

  • Single P w/ claims vs. multiple Ds
  • Counterclaims

Originally 3 kinds of

supplemental jurisdiction

  • Pendant claim jurisdiction e.g. P sues non-diverse

D for copyright infringement and also wants to sue for state law claim against same defendant

  • Pendant party jurisdiction As above, but second

state law claim against different D

  • Ancillary jurisdiction – Related claims asserted by

D as counterclaim or other additional parties after initial complaint

United Mine Workers v. Gibbs

  • Leading case on pendant claim jurisdiction
  • State the plaintiff’s causes of action, indicating

whether each is a federal or state law claim

  • What is the procedural history?
  • What is the issue for the U.S. Supreme Court to

decide?

  • How did the Supreme Court rule on this issue?

Rationale in Gibbs

  • According to Justice Brennan, what is the Constitutional source for exercising jurisdiction over pendant state claims
  • When does a federal court have power to exercise pendant jurisdiction?
  • Must that power be exercised in every case where it exists?
  • What is the policy justification for pendant claim jurisdiction?

U.S. Constitution Article III

section 2

  • The judicial Power shall extend to all Cases,

in Law and Equity, arising under this

Constitution, the Laws of the United States,

and Treaties made, or which shall be made,

under their Authority;--

  • Operative word is “Cases”

Federal Claim is dismissed

before trial

  • According to Gibbs, how should dismissal

before trial of the federal claim affect the

issue of whether or not to refuse jurisdiction

over the state law claim?