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US Civil Procedure for International Students: 2020 - 2021 Edition

Reeder v. Succession of Palmer

This case was decided before the passage of 28 U.S.C. § 1367, which now governs supplemental jurisdiction. While we did not go deep into the cases that developed the doctrine of pendent jurisdiction, you will remember that before the adoption of § 1367 a line of cases developed the doctrine of pendent jurisdiction, which addressed essentially the same issue. We can see no reason why the shift to supplemental jurisdiction under § 1367 would change the court's analysis.