paulshortys10 wrote:Can anyone teach me Supplemental Jurisdiction? I know that its a way of circumventing the SMJ requirements, but I am having trouble learning exactly when it applies and to which parties claims/joinders, and whether diversity need not be broken.
Ok, doing this because I think it will be helpful for me to actually write this out.
Federal Courts must have Subject Matter Jurisdiction (power to decide the matter) and Personal Jurisdiction (power over the parties to the suit). When determining if the court has SMJ, the Predominate Claim
must fall under two categories:
1. Federal Question - a claim that arises under federal law.
2. Diversity - (1) No single plaintiff may be a citizen of the same state as any single defendant at the time the lawsuit is filed and (2) the amount in controversy exceeds $75,000 (AIC >$75k).
When there are multiple claims in the dispute, supplemental jurisdiction is the policy that allows a federal court to decide a legal question normally tried in state courts. Claims that normally fall under state jurisdiction must share a common nucleus of operative fact (CNOF) with the Predominate Claim to be litigated in federal court. If the Predominate Claim is based on a Federal Question, then diversity does not matter.
This applies to any new parties, claims, anything.
However, when Predominate Claim is based on federal SMJ due to Diversity
(instead of a Federal Question), then, if using supplemental jurisdiction to bring in additional claims or parties, diversity must be maintained when adding new parties or claims to the suit (otherwise it could be litigated in state court).
Below are the requirements to maintain Diversity, so that Supplemental Jurisdiction can still be used to bring in the new claim/party. Permissive Joinder
: CNOF + Diversity (AIC new party >$75k not required)Compulsory Joinder
: CNOF + Diversity (AIC new party >$75k not required) Note: Supplemental jurisdiction in this matter is tricky. The court looks at a variety of factors, like whether the party was intentionally originally left out of the claim so the case could be brought in federal court. Counterclaims
: CNOF + Diversity, (AIC for new claim >$75k not required)Cross Claims
: CNOF (No AIC, No Diversity needed)Intervenors
: CNOF + DiversityInterpleaders
: CNOF + DiversityFederal Statutory Interpleaders
: CNOF + Diversity (between the Stakeholder and ANY defendant) + AIC > $500
Basically, if the jurisdictional basis for the Predominate Claim
is Diversity, adding additional parties or claims using supplemental jurisdiction must not destroy diversity, with the exception of cross claims and sometimes compulsory joinders.