Venue: |
SCOTUS
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Facts: |
Gibbs was a mine superintendant, and he claims the mine owners agreed
to open a new mine for him to supervise. He's alleging both tortious
interference with a contract and a violation of dederal labor law. |
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Posture: |
Not obvious. This is quite heavily edited. |
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Issue: |
Can a federal trial court exercise supplemental jurisdiction over his
state claim? |
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Holding: |
Yes. |
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Rule: |
If the state and federal claims derive from a common nucleus of
operative fact, the federal court can hear them both. |
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Reasoning: |
The FRCP encourages joinder and consolidation. Federal courts have
jurisdiction whenever there's a case arising under the constitution.
Federal courts can always dismiss state claims (and leave them,
therefore, for the state courts), but if its the kind of thing
where you'd expect both claims to be resolved in a single trial,
then go ahead. At the same time, though, litigants can't foist
a state law case on the federal courts: if the federal claim is
"only an appendage" to the real body of the state claim, the state
claim can be dismissed. |
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Dicta: |
Federal courts aren't obliged to exercise this power in every case where
they could. And we want to avoid needless decisions of state
law where possible. |
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