Also known as:supplemental jurisdiction · § 1367 jurisdiction
Written by attorneys · grounded in primary & secondary sources — see below
A doctrine authorizing federal district courts to exercise jurisdiction over claims that form part of the same case or controversy under Article III as claims within the court's original jurisdiction. The additional claims must share a common nucleus of operative fact with the anchor claim. In diversity cases the doctrine does not permit plaintiffs to circumvent the complete-diversity or amount-in-controversy requirements of section 1332.
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Cases
Statutes
Study Supplements
How it applies
Common Examples
4
Diversity Amount-In-Controversy Addition
Sierra Santos sued Sterling Manufacturing in federal court under diversity jurisdiction for $90,000 in contract damages. She then joined an additional state-law claim against the same defendant for $40,000 arising from the identical shipment. Because the two claims share a common nucleus of operative fact and complete diversity already exists, the court exercises supplemental jurisdiction over the smaller claim even though it falls below the jurisdictional amount.
Federal-Question Pendent Claim
Sabrina Shah filed a federal copyright-infringement action against Stonehaven Properties. In the same complaint she added a state unfair-competition claim based on the identical copying of architectural plans. The state claim shares the same operative facts as the federal claim, so the district court may exercise supplemental jurisdiction over it under section 1367(a).
Common Nucleus in Federal-Question Case
Stephen Shaw sued Summit Bank in federal court alleging a federal securities violation arising from a single loan transaction. He also asserted a state-law breach-of-fiduciary-duty claim based on the same loan documents and negotiations. The claims derive from a common nucleus of operative fact, permitting the court to hear the state claim under supplemental jurisdiction.
Diversity Impleader Bar
Stella Shapiro, a citizen of State A, sued Samantha Stone, a citizen of State B, in federal court under diversity jurisdiction. Stone impleaded a third-party defendant who is also a citizen of State A. Because the third-party claim is asserted by the plaintiff against a Rule 14 party and would destroy complete diversity, section 1367(b) bars supplemental jurisdiction over that claim.
Common questions
Frequently Asked
5
When may a federal court decline to exercise supplemental jurisdiction?+
A district court may decline supplemental jurisdiction under section 1367(c) when the claim raises a novel or complex issue of state law, when the state claims substantially predominate, when the court has dismissed all claims over which it has original jurisdiction, or when other compelling reasons exist.
Does supplemental jurisdiction allow aggregation of claims to meet the amount-in-controversy requirement in diversity cases?+
In diversity cases, if at least one plaintiff's claim satisfies the amount-in-controversy requirement and complete diversity exists, section 1367 permits supplemental jurisdiction over additional claims by joined plaintiffs that do not independently meet the jurisdictional amount, provided the claims share a common nucleus of operative fact.
What limitation does section 1367(b) impose in diversity actions?+
Section 1367(b) bars supplemental jurisdiction over claims by plaintiffs against persons made parties under Rules 14, 19, 20, or 24, or over claims by persons proposed to be joined as plaintiffs under Rule 19 or seeking to intervene under Rule 24, when exercising jurisdiction would be inconsistent with the requirements of section 1332.
What standard determines whether claims form part of the same case or controversy?+
Claims form part of the same case or controversy when they derive from a common nucleus of operative fact such that a plaintiff would ordinarily be expected to try them all in one judicial proceeding.
Can supplemental jurisdiction extend to claims involving joinder of additional parties?+
Yes. Section 1367(a) expressly includes claims that involve the joinder or intervention of additional parties when those claims are sufficiently related to the original claim.
Civil ProcedureJurisdiction and venue · Federal subject-matter jurisdictionNEXTGENFoundational