Supplemental Jurisdiction: Bringing Related Claims in Federal Court

When you file a lawsuit in federal court, you might have related claims that fall under state law. "Supplemental jurisdiction" allows federal courts to hear these related state claims alongside the federal ones, streamlining the legal process. This power is defined by 28 U.S.C.A. § 1367.

What is Supplemental Jurisdiction?

Essentially, if your state law claims are part of the same "case or controversy" as your federal claims (as defined by Article III of the Constitution), a federal court can hear them. This includes claims involving the addition of parties to the lawsuit.

The Gibbs Test:

The foundation of supplemental jurisdiction comes from the Supreme Court case United Mine Workers v. Gibbs. This case established that federal courts can hear state law claims that share a "common nucleus of operative fact" with the federal claims. In simpler terms, if the federal and state claims are closely connected, a federal court can hear them all. This principle was further discussed in cases like City of Chicago v. International College of Surgeons, 522 U.S. 156 (1997), and Finley v. U.S., 490 U.S. 545 (1989).

Discretionary Power:

It's important to understand that supplemental jurisdiction is discretionary. A federal court can hear related state claims, but it doesn't have to. Under 28 U.S.C.A. § 1367(c), a court might decline to exercise supplemental jurisdiction if:

• The state claim raises a novel or complex issue of state law.
• The state claim significantly dominates the federal claims.
• The federal claims have been dismissed.
• There are other compelling reasons to decline jurisdiction. This was also mentioned in Royal Canin U. S. A., Inc. v. Wullschleger, 604 U.S. 22 (2025).

Key Supreme Court Rulings:

• Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005), confirmed that once a court has original jurisdiction over some claims, it can exercise supplemental jurisdiction over related claims within the same case or controversy.
• City of Chicago v. International College of Surgeons, 522 U.S. 156 (1997), reiterated that federal courts' jurisdiction over federal questions includes jurisdiction over state claims arising from a common set of facts.

In Summary:

Supplemental jurisdiction allows federal courts to efficiently handle related state and federal claims. However, it's a discretionary power, and courts may decline to exercise it in certain situations to maintain the appropriate balance between federal and state judicial authority.