Also known as: operative fact
Written by attorneys · grounded in primary & secondary sources — see below
An aggregation of events and circumstances that give rise to one or more legal claims. These facts determine whether claims share a common nucleus sufficient for a federal court to exercise supplemental jurisdiction over claims lacking an independent basis for federal subject-matter jurisdiction.
Odilia Okamura and Orion Orlov, citizens of different states from the defendant seed company, sued together in federal court after a single defective seed batch destroyed their separate harvests. Odilia's losses exceeded the amount-in-controversy threshold while Orion's fell short. The court exercised supplemental jurisdiction over Orion's claim because both plaintiffs' injuries arose from the identical distribution event and growing conditions.
Opal Okoro sued a seed company in federal court on a federal labeling claim and added state-law nuisance and crop-damage claims against two additional distributors. All claims stemmed from the same seeds and cross-pollination events affecting her farm. The court exercised supplemental jurisdiction over the state claims because they derived from the same transaction or occurrence as the federal claim.
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Orson Ochoa robbed three victims during a single tavern hold-up. After acquittal on charges involving two victims, the state sought to prosecute him for the third. The court held that the operative facts of the tavern incident were identical across all charges, so double jeopardy barred the second trial.
Orla O'Malley and other clinic operators challenged state abortion restrictions in a pre-enforcement facial suit. After enforcement produced new clinic closures and patient burdens, they filed an as-applied challenge. The court permitted the second suit because material operative facts arising after the first decision created a distinct transaction.
Onyx O'Reilly, injured in an out-of-state accident, sued the driver in Minnesota and sought to base jurisdiction on the driver's insurer doing business there. The court held that the insurance contract was unrelated to the operative facts of the negligence claim and therefore could not supply minimum contacts.
Orion Orlov was convicted under a jury-selection practice later held unconstitutional. On federal habeas he sought to apply the new rule. The court refused because the new constitutional rule did not alter the operative facts of his trial and therefore did not apply retroactively to cases already final.
The plaintiff must demonstrate that the claims arise from the same transaction or occurrence so that the facts underlying each claim substantially overlap. Courts examine whether the evidence needed to prove one claim would also prove the other.
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No. When one plaintiff's claim satisfies the amount requirement and complete diversity exists, supplemental jurisdiction extends to additional plaintiffs' claims that share a common nucleus of operative fact.
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Courts compare the facts that existed at the time of the first judgment with any material facts that arose afterward. If the later facts form a new transaction when combined with earlier ones, a second action is not barred.
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…power in federal courts to hear the whole," the Court said, when the state and federal claims "derive from a common nucleus of operative fact" and are so linked that the plaintiff "would ordinarily be expected to try them all in one judicial proceeding." Id. , at 725. Gibbs involved the linkage of federal and state claims…