Supplemental Jurisdiction Overview
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Questions and Answers

§1367(a) allows federal courts to hear state law claims that do not fall under federal jurisdiction as long as they form part of the same case or controversy with an action that the court has original jurisdiction over (§1331 OR §______)

1332

The Gibbs test establishes that the same common nucleus of ______ fact is required for supplemental jurisdiction.

operative

Even if the basic requirements of §1367(a) and (b) are met, federal district courts have discretion to decline to exercise supplemental jurisdiction under certain circumstances, such as novel or complex state law ______.

issues

If a federal district court declines to exercise SMJ over an eligible state law claim, the passing of the applicable statute of limitations is ______ while the claim was in federal court and for 30 days after dismissal.

<p>tolled</p> Signup and view all the answers

The first question to ask is whether §1367(a) grants supplemental jurisdiction, and the answer is yes if it meets the ______ (CNOF).

<p>Gibbs</p> Signup and view all the answers

Supplemental Jurisdiction allows federal courts to hear state claims that are not within their original jurisdiction as long as those state claims are sufficiently related to one or more claims that are within the original ______.

<p>jurisdiction</p> Signup and view all the answers

Before 1990, the doctrine known as ______ jurisdiction allowed state and federal claims to derive from a common nucleus of operative fact.

<p>pendent</p> Signup and view all the answers

Ancillary Jurisdiction allows a federal court to hear a claim that would normally be outside of its subject-matter jurisdiction if it is substantially related to a second claim that is within the court’s ______.

<p>jurisdiction</p> Signup and view all the answers

Post 1990, Article III dictates that a plaintiff’s claims are related enough to their federal law claims that they all form a single ______.

<p>case</p> Signup and view all the answers

The statute providing the basis for Supplemental Jurisdiction is found in ______ U.S.C.

<p>28</p> Signup and view all the answers

Study Notes

Supplemental Jurisdiction

  • Supplemental jurisdiction allows federal courts to hear state law claims that aren't within their original jurisdiction (e.g., §1331 or §1332), if those state claims are sufficiently related to at least one claim that is within federal jurisdiction.

Jurisdictional Approaches (Pre-1990 vs. Post-1990)

Pre-1990

  • Pendent Jurisdiction (Gibbs): State and federal claims must derive from a common nucleus of operative fact.
  • Ancillary Jurisdiction (Owen): A federal court can hear a claim outside its jurisdiction if it's substantially related to a claim already within its jurisdiction.

Post-1990 (Modern)

  • Article III: Plaintiff's claims are related enough to form a single case.
  • Statutory Basis (28 U.S.C. §1367): Allows federal courts to hear state claims related to federal claims in the same case or controversy.
    • Two tests for case or controversy:
      • Strict Relatedness (majority): The Gibbs "common nucleus of operative fact" test.
      • Loose Factual Connection Test (minority): A less stringent standard.
    • Diversity Only Cases (1332 Exception): No supplemental jurisdiction for sole diversity cases.

Discretion in Exercising Supplemental Jurisdiction (28 U.S.C. §1367(c))

  • Federal courts have discretion to decline supplemental jurisdiction if:
    • The state law claim is novel or complex.
    • The state claim is the predominant purpose of the suit (significantly larger than the federal claim).
    • The federal claims are dismissed.
    • Exceptional circumstances exist.

Tolling of Statutes of Limitations (28 U.S.C. §1367(d))

  • If the federal court declines to exercise supplemental jurisdiction, the applicable statute of limitations is tolled (paused) during the federal court proceedings and for 30 days after dismissal.

Key Considerations

  • A federal court should first determine if §1367(a) grants supplemental jurisdiction based on the "common nucleus of operative fact" (CNOF) test.
    • The CNOF test is almost always met with claims arising from the same transaction or occurrence.
  • Then, determine if §1367(b)(2) or (c) removes jurisdiction.

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Description

This quiz explores the concept of supplemental jurisdiction in federal courts, focusing on the differences between pre-1990 and post-1990 approaches. It highlights key principles such as pendent jurisdiction, ancillary jurisdiction, and the modern statutory basis from 28 U.S.C. §1367. Test your understanding of how federal courts can hear state law claims related to federal claims.

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