Supplemental Jurisdiction Flashcards
Supplemental jurisdiciton is a form of…
federal SMJ.
Supplemental jurisdiction does not get cases into federal court, instead, it gets…
claims into a federal case.
When joining an additional claim to a federal case, first - determine if the additional claim…
meets the requirements for diversity or federal question jurisdiction.
(TRUE/FALSE): A federal court must have SMJ over every claim in a case.
TRUE.
If there is no federal SMJ over an additional claim…
it cannot be asserted in the pending case in federal court.
[Unless Supplemental]
If an additional claim does satisfy either diversity or federal question jurisdiction, then..
it may be joined in the pending federal court case.
If an additional claim does not independently satisfy federal SMJ requirements, then it may only be heard if it…
invokes supplemental jurisdiction.
HYPO: Plaintiff, citizen of North Carolina, sues Defendant, citizen of South Carolina, for $100K from a car accident. Defendant files a counterclaim against the Plaintiff for a state law tort claim for $125K. Does the federal court need use supplemental jurisdiction to hear the counterclaim?
No – the counterclaim also invokes diversity jurisdiction.
HYPO: Plaintiff, citizen of North Carolina, sues Defendant, citizen of South Carolina, for $100K from a car accident. Defendant files a counterclaim against the Plaintiff for a state law tort claim for $50K. Does the federal court need use supplemental jurisdiction to hear the counterclaim?
Yes – the counterclaim does not meet diversity jurisdiction requirements (AiC). Must be brought in through supplemental jurisdiction.
Claims will meet supplemental jurisdiction requirements if they arose from…
a common nucleus of operative fact as in the existing federal court case.
“Same transaction or occurrence” always satisfies the common nucleus test.
HYPO: Plaintiff, citizen of Florida, sues Defendant, citizen of Georgia, on a state law claim for $250K in federal court. In this case, Defendant wants to assert a counterclaim based on state law against the Plaintiff for $50K. The counterclaim arises from a completely separate factual event from the Plaintiff’s claim. Can the counterclaim invoke supplemental jurisdiction?
No – it does not meet the common nucleus test.
In a diversity jurisdiction claim, additional claims brought by Plaintiff’s can generally…
NOT invoke supplemental jurisdiction.
HYPO: An Ohio Plaintiff sues an Ohio Defendant for two claims, one arising under federal antitrust laws and the other is a state antitrust claim, based on the same conduct. May claim 2 be heard alongside claim 1 in federal court?
Yes – it arises under the same common nucleus of operative facts.
The one exception to the limitation of the use of supplemental jurisdiction for additional claims brought by the Plaintiff in diversity cases applies only when…
there are multiple Plaintiffs and the claim by one of them does not meet the AiC requirement.
HYPO: P1, citizen of Virginia, and P2, citizen of Virginia, sue Defendant, citizen of Pennsylvania on state law tort claims. P1’s claim is for $100K. P2’s claim arises from the same transaciton or occurrence, but is for only $50K. Can the claim by P2 invoke supplemental jurisdiction?
Yes. (1) It meets the common nucleus test, and (2) Even though this is a claim by a Plaintiff in a diversity case, the limitation does not apply because there are multiple Plaintiff’s and P2’s claim is below-limit.
