0 0
Supreme Court of the United States - 490 U.S. 545
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.
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.
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.
LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.
Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.
Lawyers and judges love to use big words. And Latin, for some reason.
Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.
DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.
Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.
Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.
Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.