| Venue: | SCOTUS |
| Facts: | Finley's husband and 2 kids die in a plane crash: they hit power lines. |
| Posture: | Suit in state court, alleging that SD G&E was negligent in positioning the power lines, and that the city of San Diego was negligent in maintenance of runway lights. But then it turns out that the FAA is responsible for th light, so suit is filed in federal court (under the Federal Tort Claims Act). One year later, the complaint is amended to include claims against the original state-court defendants, without an independent basis for federal jurisdiction, reasoning that United Mine Workers v. Gibbs makes this OK, since there was a common nucleus of operative facts. District court sends an interlocutory to the 9th circuit. They reverse. |
| Issue: | Does the FTCA permit an assertion of pendent jurisdiction over additional parties? |
| Holding: | No. Affirmed. |
| Rule: | In order for a federal court to have jurisdiction, the constitution must have given the court capacity to take the case, and an act of congress must have actually supplied jurisdiction. Basically, the district court can't extend its jurisdiction to cover parties over whom it has no basis for jurisdiction. |
| Reasoning: | The parties here are different from those in United Mine Workers v. Gibbs, in the sense that they're not named in any claim that could be brought in federal court. The convenience of the litigants and concerns of judicial economy are not sufficient to extend ancillary jurisdiction this way. The FTCA doesn't contain any such broad grant. |
| Dicta: | Stevens (dissenting): The doctrine of pendent jurisdiction recognizes that forcing a litigant to try a case in both federal and state courts impairs the ability of the federal court to grant full relief, and imparts a bias against bringing suits in federal courts, because of the deterrent effects of duplicate litigation. |