United Mine Workers v. Gibbs
Citation: 383 U.S. 715 (1966)
Facts
Gibbs, a Tennessee mine superintendent, sued United Mine Workers in federal court under federal labor law (LMRA) and also asserted state tort claims arising from the same dispute — a violent labor dispute that cost him his job and his haulage contract. He sought to litigate both claims in federal court.
Issue
May a federal court exercise jurisdiction over a state-law claim that lacks independent federal jurisdiction, when the state and federal claims derive from a common nucleus of operative fact?
Holding
Yes. A federal court may exercise “pendent” (now supplemental) jurisdiction over state-law claims that are so related to the federal claims as to form part of the same case or controversy. The state claims need not independently satisfy federal jurisdiction requirements.
Rule
Pendent (supplemental) jurisdiction: Federal courts have constitutional power to hear related state claims when: (1) the federal and state claims derive from a common nucleus of operative fact, and (2) the plaintiff would ordinarily be expected to try them all in one judicial proceeding. The court retains discretion to decline pendent jurisdiction when: state issues predominate, the federal claims are dismissed early, or jury confusion would result.
Now codified at 28 U.S.C. § 1367 (Supplemental Jurisdiction).
Significance
- Foundational case for supplemental (pendent) jurisdiction doctrine
- Gibbs test still governs whether § 1367(a) is satisfied: “same case or controversy” = common nucleus of operative fact
- Federal courts retain discretion under § 1367(c) to decline supplemental jurisdiction in specified circumstances
- Extended in Owen Equipment & Erection Co. v. Kroger (limits on pendent party jurisdiction) and then resolved by § 1367