Supplemental Jurisdiction: Statute & Examples

Supplemental Jurisdiction: Statute & Examples
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  • 0:03 No Jurisdiction, No Case
  • 1:00 State Courts vs.…
  • 2:38 Supplemental Jurisdiction
  • 4:53 Lesson Summary
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Instructor: Kenneth Poortvliet
Federal courts' jurisdiction over disputes that arise between state citizens is limited by the U.S. Constitution and federal statutes. Supplemental jurisdiction expands those limits, and in this lesson, we will explore just how that works.

No Jurisdiction, No Case

Shots rang out in Barry's Cabana, and Tony lay dead. Tony's family sued Barry's Cabana for not providing security, and they filed in federal court. Right before trial, Barry's Cabana's attorney added Rico to the suit, saying that he was the one who shot Tony. The family's attorney called and said their case was dismissed from federal court and that they'd have to start all over in state court. Needless to say, the family wasn't happy. How could they do that?

Jurisdiction is the power of a court to hear a case. Without that power, that court can't hear that case. There are three types of jurisdiction that every court must have to hear any case: territorial jurisdiction, which is authority over the area where the court sits; in personam jurisdiction, also known as 'personal,' which is power over the parties of a case; and subject matter jurisdiction, which is authority over the subject of the dispute.

State Courts vs. Federal Courts

Article III of the Constitution lays out the authority for federal cases: it says federal courts have authority to hear all cases 'in law and equity, arising under this Constitution, the laws of the United States'. This means that federal courts can hear cases involving a constitutional issue, federal laws (called federal question jurisdiction), and treaties.

For jurisdiction, this means when a case arises between two citizens of a state that is not an issue involving the Constitution or a federal law, then the federal court has no jurisdiction. Article III also gives the federal courts authority to hear cases arising between two citizens of different states, and this is called diversity jurisdiction. A federal statute, 28 U.S.C. Sec. 1332, outlines the requirements for diversity jurisdiction as a dispute between citizens of two different states and an amount in controversy over $75,000.

For example, lets say Kia sues his neighbor Su, who lives across the state line, for damage done by Su's dog when the dog jumped Kia's fence and ate his prized petunias worth $90,000. If Kia wanted to sue in federal court, he could because he and Su live in two different states, and the amount in controversy is over $75,000. But what if Su didn't live in a different state? Then Kia could still sue, but only in state court. However, if the petunias were protected by federal law, he could sue in federal court (and the amount of the suit wouldn't matter) because at the center of the suit is a federal law. Thus, there is federal question jurisdiction.

Supplemental Jurisdiction

The question then becomes, what happens if a claim or a party is added to the suit? Does that change the authority of the court to hear that case? If Su cross claims (sues a third party who is connected to the facts) the fence maker, over a defective fence, does the federal court retain authority? The court has diversity jurisdiction because Su and Kia are in different states, but there is no diversity between the fence maker and Su, so she couldn't be added to the suit.

Likewise if the suit was based on federal question, (remember the federally protected petunias), then there is no federal question jurisdiction between Su and the fence maker. This is where supplemental jurisdiction comes in. Supplemental jurisdiction is 'the authority of United States federal courts to hear additional claims substantially related to the original claim even though the court would lack the subject matter jurisdiction to hear the additional claims independently.'

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