Finley v. United States
Citation and Court
490 U.S. 545 (1989) — Supreme Court of the United States
Facts
Thalis Finley’s husband and children were killed when their plane struck power lines near a San Diego airport. Finley sued the United States under the Federal Tort Claims Act (FTCA) in federal district court. She sought to add pendent claims against the city and utility company (non-diverse parties over whom no independent federal jurisdiction existed). The district court dismissed the pendent claims for lack of jurisdiction.
Issue
Whether a federal district court has pendent-party jurisdiction to hear state-law claims against non-diverse defendants joined to an FTCA suit against the United States.
Holding
No. Federal courts lack pendent-party jurisdiction to entertain claims against parties over whom no independent basis of federal jurisdiction exists; such jurisdiction requires affirmative statutory authorization.
Rule / Doctrine
Pendent-party jurisdiction — extending the court’s jurisdiction to new parties rather than merely new claims — requires express congressional authorization. The constitutional power to hear such claims (Gibbs) is a necessary but not sufficient condition; a statutory grant is also required.
Significance
Finley prompted Congress to enact 28 U.S.C. § 1367, the supplemental jurisdiction statute, in 1990, effectively superseding Finley’s holding. The case thus illustrates how Supreme Court decisions limiting jurisdiction can catalyze legislative expansion of federal court power. It is now taught primarily as the background for understanding § 1367.