Cases on Supplemental Jurisdiction

This section summarizes three Supreme Court decisions handed down after Gibbs but before the passage of 28 U.S.C. § 1367.

When you encounter a supplemental jurisdiction situation, you should begin with § 1367, not with Gibbs or these cases. So, you might ask, why do I make you read them. § 1367, like many statutes, uses terminology and phrasing that is hard to understand. Congress had Gibbs and the following three cases in mind when it wrote the statute, so knowing them will help you understand the statute. Second, courts interpret § 1367 in light of these cases, so knowing them will help you predict what courts will do.

To understand these three cases, ask yourself the following question about each one, as you read it:

1) What is the basis of subject matter jurisdiction for the theory of relief over which the district court unquestionably has jurisdiction?

      a) I will refer to that theory of relief as the "anchoring claims." Courts and commentators often call it the "original jurisdiction" claim.

      b) There may be more than one anchoring claim.

2) Did the plaintiff in each case seek to add "only" a new claim against a party already subject to an anchoring claim, or to add a party as to which there was no anchoring claim?

3) What was the reason why the Court allowed, or denied, the plaintiff's attempt to exercise what we now call supplemental jurisdiction?

4) Analyze each fact pattern according to § 1367. Had § 1367 been in existence at the time of each case, would the result have been the same or different?

To understand Aldinger, you'll want to review the summary of 42 U.S.C. § 1983 from the "Utterly Oversimplified Summary of Three Causes of Action" document from Day 1.