The Oyez Project: Judicial Power Issues - Ancillary or Pendent Jurisdiction Decisions

Aldinger v. Howard

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City of Chicago v. International College of Surgeons

May a lawsuit filed in the Circuit Court of Cook County seeking judicial review of decisions of the Chicago Landmarks Commission be removed to federal district court, where the case contains both federal constitutional and state administrative challenges to the Commission's decisions?

Yes. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that a case containing claims that local administrative action violates federal law, but also containing state law claims for on-the-record review of the administrative findings, can be removed to federal district court. The Court reasoned that the landowners' actions fell within the District Court's original jurisdiction over federal questions and that the court could exercise supplemental jurisdiction over the state claims. "Because neither the jurisdictional statutes nor our prior decisions suggest that federal jurisdiction is lacking in these circumstances, we now reverse," wrote Justice O'Connor. Justice Ruth Bader Ginsburg wrote a dissent, in which Justice John Paul Stevens joined.

Exxon Corp v. Allapattah Services

In a civil action where one plaintiff's claim satisfies the minimum amount-in-controversy requirement for federal diversity jurisdiction, and another plaintiff's related claim does not, does 28 U.S.C. Section 1367 allow federal courts to exercise supplemental jurisdiction over the claim that is less than the required amount?

Yes. In a 5-4 decision, the Court ruled that as long one plaintiff meets the amount-in-controversy requirement for federal jurisdiction, Section 1367 authorizes federal courts to exercise supplemental jurisdiction over related claims even if they do not meet the requirement. The majority opinion by Justice Anthony Kennedy held that courts only need to determine whether they have original jurisdiction over one of the claims in a case. If they do, courts can then decide to extend supplemental jurisdiction to the other related claims. The Justices ruled that to require each claim in a civil action to meet the requirement would be "inconsistent with the whole notion of supplemental jurisdiction." The Court based its ruling on the "unambiguous[]" text of the statute, saying "the authoritative statement is the statutory text, not the legislative history or any other extrinsic material." Justice Stevens, joined by Justice Breyer, wrote a dissenting opinion arguing that the Court should have consulted the legislative history of Section 1367. Justice Ginsburg, joined by Justices Stevens, O'Connor, and Breyer, wrote a dissent arguing for a narrower interpretation of Section 1367 that would not overturn Zahn.

Mine Workers v. Gibbs

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Owen Equipment & Erection Co. v. Kroger

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Peacock v. Thomas

Do federal courts possess ancillary jurisdiction over new actions in which a federal judgment creditor seeks to impose liability for a money judgment on a person not otherwise liable for the judgment?

No. In an 8-1 opinion delivered by Justice Clarence Thomas, the Court held that the District Court lacked jurisdiction over Thomas's subsequent suit. The Court found that neither ERISA's jurisdictional nor the general federal question jurisdictional provision supplied the District Court with subject matter jurisdiction over the suit against the corporate officer. The Court noted that is was unaware of any provision under ERISA for imposing liability under the circumstances for an extant ERISA judgment against a third party. Justice John Paul Stevens, in a dissent, argued that a federal court's jurisdiction encompasses a claim by a judgment creditor that a party in control of the judgment debtor has fraudulently exercised that control to defeat a judgment.

Raygor v. Regents of the University of Minnesota

Does the federal supplemental jurisdiction statute's tolling provision apply to claims filed in federal court against nonconsenting States?

No. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the Board of Regents of the University of Minnesota never consented to suit in federal court on Raygor and Goodrich's state law claims and that the federal supplemental jurisdiction statute does not toll the period of limitations for state law claims asserted against nonconsenting state defendants that are dismissed on Eleventh Amendment grounds. Therefore, Justice O'Connor reasoned that the federal supplemental jurisdiction statute did not operate to toll the period of limitations for Raygor and Goodrich's claims. Justice Ruth Bader Ginsburg filed an opinion concurring in part and concurring in the judgment. Joined by Justices David H. Souter and Stephen G. Breyer, Justice John Paul Stevens dissented.