Plant v Blazer Financial Services

1979

Kind of a lame use of an ordered list, eh?
Venue: 5th Cir.

Facts: Plant borrows $2,520 from Blazer and never makes any payment. Then a year later she sues under the truth-in-lending act.

Posture: Counterclaim for the unaid balance. The court finds that Blazer did fail to disclose some stuff, awards Plant a total of $1,644.76. Court also finds for Blazer on the unpaid debt, so she owes the difference. She appeals.

Issue: Three of them, initially, but we're only concerned with one:
  1. Did the court have jurisdiction to hear the counterclaim?

Holding: Yes, affirmed.

Rule: Debt counterclaims are compulsory.

Reasoning: If a counterclaim is compulsory, it's covered by supplemental jurisdiction. There are four tests available to decide:
  1. Are the issues of fact and law largely the same?
  2. Would res judicata bar a subsequent suit on the defendant's claim?
  3. Will substantially the same evidence be used to support or refute either claim?
  4. Is there a logical relation between claim and counterclaim?
Test #4 is the most common, and it's nice and flexible.

Dicta: