Supplemental Jurisdiction (28 U.S.C. § 1367)
“In any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution.”
Codified the doctrines of pendent jurisdiction (United Mine Workers v. Gibbs, 1966) and ancillary jurisdiction into a single statute (enacted 1990).
§ 1367(a) — Grant of Supplemental Jurisdiction
Covers claims that are part of the same Article III case or controversy as a claim with original jurisdiction — i.e., they share a common nucleus of operative fact with the federal claim (Gibbs).
Includes claims by or against parties joined under Rules 14, 19, 20, or 24 (impleader, required parties, permissive joinder, intervention).
§ 1367(b) — Diversity Exception
In diversity cases only (not federal question), no supplemental jurisdiction over claims:
- By plaintiffs against persons joined under Rule 14, 19, 20, or 24 if such jurisdiction would be inconsistent with § 1332 (i.e., would destroy complete diversity or fall below $75,000)
- This prevents plaintiffs from using supplemental jurisdiction to circumvent diversity requirements
Exxon Mobil Corp. v. Allapattah Services (2005): § 1367 overrules Zahn v. International Paper Co. — once one plaintiff satisfies the amount-in-controversy requirement, the court has supplemental jurisdiction over claims by other plaintiffs in the same class that do not independently satisfy the threshold.
§ 1367(c) — Discretionary Declination
Court may decline supplemental jurisdiction when:
- The claim raises a novel or complex issue of state law
- The supplemental claim substantially predominates over the federal claim
- The court has dismissed all claims with original jurisdiction
- There are other compelling reasons
Carnegie-Mellon Univ. v. Cohill (1988): courts have equitable power to remand (not just dismiss) pendent state claims.
§ 1367(d) — Tolling
Statute of limitations is tolled for any supplemental claim while it is pending in federal court, plus 30 days after dismissal.