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Finley v. United States

(1989)

Supreme Court of the United States - 490 U.S. 545

tl;dr:

Pendent party jurisdiction may not allow the federal courts to adjudicate a claim against a party who would not otherwise be subject to federal jurisdiction simply because it arose from a common nucleus of operative fact as a claim against another party

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Case Summary

In the 1989 case Finley v. United States, the Supreme Court dealt with an issue of pendent party jurisdiction, which refers to a court's ability to hear additional claims in a lawsuit that arise from the same set of facts as the main claim. The dispute reached the Supreme Court after the Ninth Circuit Court of Appeals overturned the District Court's decision to allow state law claims against a city and utility company in a lawsuit under the Federal Tort Claims Act (FTCA).

Finley, the plaintiff, argued that the lower court's decision was correct based on the Mine Workers v. Gibbs legal doctrine. The main question was whether pendent party jurisdiction should apply to state law claims that shared a common nucleus of operative fact with a federal claim under the FTCA.

The Supreme Court ruled that pendent party jurisdiction was not allowed in this case because it wasn't authorized by Congress or the Constitution. The court explained that pendent party jurisdiction is a discretionary doctrine based on interpreting laws and constitutional limits. The FTCA, which allows lawsuits against the United States, doesn't automatically grant jurisdiction over additional claims involving other parties. The court also noted that allowing pendent party jurisdiction would violate the Constitution's requirement for an independent basis of federal jurisdiction for each claim and party.

This case is significant because it demonstrates how courts apply pendent party jurisdiction within the limits of the law and the Constitution, as well as respecting state sovereignty. The case is a landmark decision in federal civil procedure, with an opinion authored by Justice Scalia.

ICRAIssue, Conclusion, Rule, Analysis for Finley v. United States

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Facts & HoldingFinley v. United States case brief facts & holding

Facts:Finley's husband and two children died when a plane struck...

Holding:This encompasses the difference between pendent-party jurisdiction, versus pendent-claim jurisdiction.Plaintiff...

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Finley v. United States | Case Brief DeepDive
Majority opinion, author: Justice Scalia
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The petitioner filed a tort action against San Diego Gas and Electric Company and the city of San Diego after her family died in a plane crash caused by electric transmission lines. Later, she discovered that the Federal Aviation Administration (FAA) was responsible for the runway lights and filed a complaint against the United States under the Federal Tort Claims Act (FTCA) for negligence in the FAA's operation and maintenance of the runway lights and air traffic control functions. She then moved to amend the complaint to include claims against the original state-court defendants, which had no independent basis for federal jurisdiction. The District Court granted her motion and asserted "pendent" jurisdiction under Mine Workers v. Gibbs, finding that trying the actions together would favor judicial economy and efficiency. The Court of Appeals for the Ninth Circuit summarily reversed, rejecting pendent-party jurisdiction under the FTCA. The Supreme Court granted certiorari to resolve a split among the Circuits on whether the FTCA permits an assertion of pendent jurisdiction over additional parties. The Court must determine whether the FTCA allows for pendent-party jurisdiction over additional parties.

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Dissenting opinion, author: Justice Blackmun,Justice Stevens
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The dissenting opinion in the case argues that the Court's decision ignores established legal principles and previous rulings. The Federal courts have the power to decide cases within specified categories, and the District Court has jurisdiction over civil actions against the United States under the Federal Tort Claims Act. Rule 14(a) of the Federal Rules of Civil Procedure allows a defendant to implead joint tortfeasors, even in cases involving the FTCA. The petitioner is authorized to assert additional claims against the nonfederal defendants under Rule 20(a) of the Federal Rules. Pendent jurisdiction allows a federal court to hear a state claim that arises from a common nucleus of operative fact with a federal claim that invokes subject matter jurisdiction. However, pendent-party jurisdiction should not be exercised if Congress has expressly or by implication negated its existence in the statute granting subject-matter jurisdiction over the particular claim before the Court. Congress may withdraw or deny pendent jurisdiction over particular claims or parties. The circumstances for the exercise of pendent party jurisdiction are powerful when federal jurisdiction over claims is exclusive, making a federal court the only one where a complete disposition of federal and related state claims could be rendered.

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Finley v. United States

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