Statute Annotations › Federal › 28 U.S.C. § 1367

28 U.S.C. § 1367

Supplemental jurisdiction: the cases that interpreted this section

Jurisdiction
Federal
Case notes
23,839
Cited in passing
13,688
Citing cases indexed
52,633
Case dates
1990–2026
Screened through
2026-06-29
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

37,527 citing cases reviewed of 52,633 in the citation index: 23,839 interpreted the section (annotated below), 13,688 cited it only in passing. Cases filed after 2026-06-29 may not have been reviewed yet.

Have a situation under 28 U.S.C. § 1367?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Common nucleus of operative fact — 2020

Section 1367(a) provides no supplemental jurisdiction over a counterclaim that does not share a common nucleus of operative facts with the plaintiff’s federal claims.

Stafford v. The Bath Planet of Arkansas, LLC · filed 2020-11-23(a)

There is no supplemental jurisdiction over the defendant’s counterclaim when the counterclaim and the plaintiff’s original FLSA claims do not derive from a common nucleus of operative facts.
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Section 1367(a) requires each additional claim to share a common nucleus of operative fact with a claim within the court’s original jurisdiction; a shared employment relationship alone is insufficient.

Bright Kids NYC Inc. v. Kelly · filed 2020-11-24(a)

The scope of supplemental jurisdiction both before and after the enactment of Section 1367 has traditionally been defined as claims that share a “common nucleus of operative fact” with the underlying claim.
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Section 1367(a) permits supplemental jurisdiction over state-law claims arising from the same nucleus of operative facts as claims within the court’s original jurisdiction.

Davis v. DeSantis · filed 2020-12-01(a)

Moreover, these claims arise from the same nucleus of facts as the claims requesting a declaration of rights under state law such that this Court may properly exercise supplemental jurisdiction over them pursuant to 28 U.S.C. § 1367.
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Section 1367(a) does not extend supplemental jurisdiction to a counterclaim that lacks a common nucleus of operative fact with the federal claim, even when the claims involve the same parties.

Bailey v. Nurmi · filed 2020-12-10(a)

To test whether claims are part of the same case or controversy under Article III and Section 1367, courts ask whether the state law claim shares a “common nucleus of operative fact” with the federal claim. ... If I had supplemental jurisdiction over Nurmi’s fraud counterclaim, the “common nucleus of operative fact” test would be watered down to treat any claims between the same parties as one case or controversy.
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Section 1367(a) does not provide supplemental jurisdiction over state-law counterclaims when their only factual connection to a federal ADA claim is the parties’ employment relationship.

Krupa v. 5 & Diner N 16th Street LLC · filed 2020-12-28(a)

Here, the Court does not have supplemental jurisdiction under § 1367(a) because the Plaintiff’s ADA claims and Defendant’s state law counterclaims do not arise from a “common nucleus of operative fact.”
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Section 1367(a) does not provide supplemental jurisdiction over a claim that does not share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Warming Trends, LLC v. Flame Designz, LLC · filed 2023-01-17(a)

Because Warming Trends has failed to demonstrate that the breach of contract claim shares a common nucleus of operative fact with either the patent claim or the Lanham Act claim, the Court does not have supplemental jurisdiction over the breach of contract claim.
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Section 1367(a) permits supplemental jurisdiction over state constitutional claims based on the same alleged conduct as federal claims that survive initial review.

Inscoe v. NC Department of Public Safety · filed 2023-01-18(a)

Here, the Plaintiff asserts that her rights under North Carolina Constitution Article 1, § 27 are being violated for the same reasons that the Defendants violated her Eighth Amendment rights. ... The Plaintiff’s Eighth Amendment claims passed initial review, and the Plaintiff’s § 27 claims will likewise be allowed to proceed against NCDPS and Defendants Buffaloe, Buchanan, Carver, Fox, Goforth, Hicks Honeycutt, Jordan-Williams, Miller, Silver, Waldroop, and Watson at this time.
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Section 1367(a) does not confer supplemental jurisdiction over state claims that share only an actor and a general employment context with federal claims, without a common nucleus of operative fact.

Romano v. AC360 Media, LLC · filed 2023-01-20(a)

This minimal connection is not sufficient to create a common nucleus of operative fact, and accordingly is not sufficient to confer supplemental jurisdiction over Plaintiff’s state law tort claims.
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Section 1367(a) permits supplemental jurisdiction over a state law claim that shares a common nucleus of operative fact with a surviving federal claim.

Spiezio v. Martinez · filed 2023-01-31(a)

Moreover, the Court also finds that Plaintiff’s federal Section 1983 claims and Plaintiff’s state law automobile negligence claim derive from a common nucleus of operative facts, based on the events at issue in all of these claims.
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Section 1367 permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a claim within the court’s original jurisdiction.

GGB Management Company v. J.P. Farley Corporation · filed 2023-02-21(a)

All claims against JP Farley derive from their alleged failure to perform their contractual obligation to process or make insurance claim payments for an ERISA health-coverage plan, pursuant to the Insurance and Pharmacy Agreements. Therefore, they derive from a common nucleus of operative fact and the Court may exercise supplemental jurisdiction over the intentional misrepresentation claim against JP Farley.
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Section 1367(a) permits supplemental jurisdiction over an FAA vacatur claim that shares a common nucleus of operative fact with claims within the court’s original federal-question jurisdiction.

Searcy v. Smith · filed 2023-02-24(a)

Accordingly, having concluded that it has federal question jurisdiction over the state law claims on the basis of preemption, see supra Section III.A, the Court also concludes that it has supplemental jurisdiction over the plaintiff’s FAA vacatur claim pursuant to 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state-law counterclaims that share a common nucleus of operative fact with a federal retaliation claim.

Viviani v. Coffey and Associates Inc · filed 2023-03-09(a)

Defendant’s counterclaims derive from a common nucleus of operative fact with Plaintiff’s retaliation claim. The Court therefore has supplemental jurisdiction over these counterclaims pursuant to 28 U.S.C. § 1367(a).
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Section 1367 permits supplemental jurisdiction over state law claims sharing a common nucleus of operative fact with a surviving federal claim.

Moore v. County of Nassau · filed 2023-03-13(a)

Because one of Plaintiff’s federal claims remain and because that federal claim and Plaintiff’s state law claims “derive from a common nucleus of operative fact,” exercising pendent jurisdiction over Plaintiff’s state law claims is proper.
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Section 1367 permits a court to exercise supplemental jurisdiction over claims arising from a common nucleus of operative fact with claims within its original jurisdiction.

Rios v. Micmac Records, Inc. · filed 2023-03-14(a)

As Plaintiffs’ causes of action for unpaid royalties arise under a common nucleus of operative fact as the rest of Plaintiffs’ claims, Compl. 4 54— 59, 75-78, the Court shall exercise supplemental jurisdiction over them.
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Section 1367(a) requires a state-law claim to share a common nucleus of operative fact with the federal claim for supplemental jurisdiction.

Hernandez v. Roche · filed 2023-03-27(a)

The district court, however, denied the motion as to his business disparagement claim, determining that it lacked supplemental jurisdiction under 28 U.S.C. § 1367(a) over that claim. Specifically, after a thorough analysis, the district court concluded that Hernandez’s business disparagement claim lacked a “common nucleus of operative fact” 1 with his ADA claim such that supplemental jurisdiction was lacking. Having considered the briefing and relevant portions of the record, we conclude that the district court did not err in dismissing Hernandez’s business disparagement claim for lack of jurisdiction.
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Section 1367(a) gives federal courts supplemental jurisdiction over state law claims that arise from the same operative facts as a claim within original federal jurisdiction.

Davenport v. City of Brundidge · filed 2023-03-30(a)

Thus, the state law claims brought by the Plaintiff against the Defendants are “so related” to the § 1983 claim that “they form part of the same case or controversy.” See 28 U.S.C. § 1367(a).
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Section 1367(a) does not confer supplemental jurisdiction over state tort claims that lack a common nucleus of operative fact with the surviving federal claims, even when the claims involve different plaintiffs and defendants.

Doe v. Avon Old Farms School, Inc · filed 2023-03-31(a)

The key question then is whether Jane Doe 1’s state law claims against John Doe “derive from a common nucleus of operative fact” as her mother’s federal claims against Avon Old Farms. They do not.
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Section 1367(a) does not permit supplemental jurisdiction over state claims that share no common nucleus of operative fact with the federal claim.

Rounds v. The Board of Trustees of the California State University · filed 2023-04-20(a)

Since no common nucleus of operative facts appears to exist between Rounds’s § 1983/First Amendment retaliation claim and the proposed conversion and negligence claims, it is inappropriate for the Court to exercise supplemental jurisdiction over Rounds’s proposed conversion and negligence claims.
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Section 1367(a) does not confer supplemental jurisdiction over a state discrimination claim alongside a federal wage claim when the employment relationship is their only overlapping fact.

Miranda v. YBJ Incorporated · filed 2023-04-27(a)

The employment relationship is the only overlapping fact. Otherwise, plaintiff’s discrimination claim “simply [has] nothing to do with whether plaintiff[] [was] paid . . . overtime as required under the FLSA.” ... Accordingly, plaintiff’s NYSHRL claim must be dismissed for lack of subject matter jurisdiction.
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Section 1367(a) does not provide supplemental jurisdiction over state age discrimination claims based on disparaging comments, termination, and replacement when the federal wage claims concern pay and hours worked.

Mendez v. A. L. Contractor NY · filed 2023-05-17(a)

Here, the factual allegations underlying plaintiff's FLSA claims concern what he was paid and how long he worked. The factual allegations underlying plaintiff's discrimination claims concern disparaging comments defendant made because of plaintiff’s age, plaintiffs termination from employment, and plaintiff's replacement with a younger employee. ... Accordingly, the Court does not have supplemental jurisdiction over plaintiff's age discrimination claims, and those claims are dismissed for lack of subject matter jurisdiction.
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Section 1367(a) gives a district court supplemental jurisdiction over state-law claims sharing a common nucleus of operative fact with a claim within its original jurisdiction.

Dole v. Joshi · filed 2023-06-13(a)

Dole’s fraudulent-conveyance claim thus is connected to, and arises from, Joshi’s criminal proceeding—the same “common nucleus of operative fact” underlying her claim under 18 U.S.C. § 2255. The Court accordingly has supplemental jurisdiction over Dole’s state-law claims. 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over a state claim that shares a common nucleus of operative fact with a federal claim, including claims grounded in the same employment relationship and termination.

Carole Sawyer v. Tidelands Health ASC, LLC · filed 2023-06-15(a)

The arc, conditions, and ultimate termination of Sawyer’s employment relationship with Tidelands thus form the foundation of Sawyer’s FMLA and SCPWA claims alike, thereby placing Sawyer’s SCPWA claim within the bounds of § 1367(a)’s grant of supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over a claim that shares a common nucleus of operative fact with a claim within the court’s original jurisdiction, including claims that satisfy Rule 20’s transaction-or-occurrence requirement.

Waryck v. Thor Motor Coach, Inc. · filed 2023-06-23(a)

It follows that Plaintiffs’ claims also satisfy the common nucleus requirement for a grant of supplemental jurisdiction under § 1367.
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Section 1367(a) permits supplemental jurisdiction over claims against additional parties only when those claims share a common nucleus of operative fact with the federal claims.

Rindal v. McDermott · filed 2023-07-06(a)

Because the state law claims against Souders do not arise from the same nucleus of operative facts giving rise to his federal claims, supplemental jurisdiction does not exist.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Shanks v. International Union of Bricklayers and Allied Craftworkers · filed 2023-07-18(a)

Next, the Court finds that it has supplemental jurisdiction over Plaintiff’s state law claims pursuant to 28 U.S.C. § 1367. ... Here, Plaintiff’s federal and state law claims derive from a common nucleus of operative fact: the “harassment, retaliation, targeting, systemic discrimination, excessive discipline, pay disparity, denied promotional opportunities, vilification and bullying by upper management” that Plaintiff allegedly experienced while employed by Defendant, and his subsequent termination pursuant to Defendant’s COVID-19 Vaccination Policy.
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Section 1367 permits a court with federal-question jurisdiction to exercise supplemental jurisdiction over related state law claims that share a common nucleus of operative fact with the federal claim, subject to grounds for declining jurisdiction.

Lambert v. International Union of Bricklayers and Allied Craftworkers · filed 2023-07-18(a), (c)

Plaintiff’s Title VII claim and state law claims under “other Civil Rights Acts,” if they are to be construed as such, derive from a common nucleus of operative fact: the controversy surrounding the end of Plaintiff’s employment relating to Defendant’s COVID-19 vaccination policy. See Compl. ¶ 3; Pl.’s Mot. ¶ 3. None of the factors that may lead courts to decline to exercise supplemental jurisdiction are present. Therefore, at this time and on the present record, the Court chooses to assert supplemental jurisdiction over any state law claims that Plaintiff intended to plead, although they were not expressly articulated as such.
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Section 1367(a) does not permit supplemental jurisdiction over a state contract claim that lacks a common nucleus of operative fact with the federal patent claims.

Quicklogic Corporation v. Konda Technologies, Inc. · filed 2023-08-11(a)

As such, the Court does not have supplemental jurisdiction over QuickLogic’s non-breach of contract claim.
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Section 1367(a) permits supplemental jurisdiction over a plaintiff’s state wage claims when they arise from the same employer compensation practices as other plaintiffs’ federal wage claims, even if that plaintiff’s federal claims are untimely.

Mota v. Abalon Exterminating Company, Inc. · filed 2023-08-14(a)

Here, the NYLL claims brought by Subaran clearly arise out of the same compensation policies and practices of the same employer as the FLSA claims brought by the other plaintiffs. Accordingly, supplemental jurisdiction over Subaran’s NYLL claims is appropriate.
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Section 1367(a) does not permit supplemental jurisdiction over a state-law defamation claim that lacks a common nucleus of operative fact with the federal claim.

Balderas v. Gonzalez · filed 2023-08-17(a)

A state law defamation claim does not arise out of a common nucleus of operative fact as the plaintiff’s Fourth Amendment claim against the officers.
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Section 1367(a) provides supplemental jurisdiction over state-law claims arising from the same common nucleus of operative fact as a claim within the court’s original jurisdiction.

Meridian PO Finance LLC v. OTR Tire Group Incorporated · filed 2023-08-21(a)

Under 28 U.S.C. § 1367(a), a federal court shall have supplemental jurisdiction over all state-law claims that are within the same common nucleus of operative facts as the claim with original jurisdiction. ... Because the state-law claims arise from the same common nucleus of operative fact that gave rise to the RICO claims, the Court will exercise supplemental jurisdiction over the state-law claims.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a claim within the district court’s original jurisdiction.

Warming Trends, LLC v. Flame Designz, LLC · filed 2023-08-25(a)

The Court finds that it has supplemental jurisdiction over the breach of contract claim pursuant to 28 U.S.C. § 1367(a). The breach of contract claim arises from the same “common nucleus of operative fact” as the patent infringement claim because both claims involve defendant’s sale of the Eco Burner 2.0.
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Section 1367 permits supplemental jurisdiction over state law claims that derive from a common nucleus of operative fact with federal claims remaining in the case.

Pinkston v. The Board of Education of the City of Chicago · filed 2023-10-02(a)

The Court can reach these claims because Plaintiff’s FAC contains federal causes of action beyond that asserted in Count I, and the state law claims asserted against Miller and Smith “derive from a common nucleus of operative fact” as these other federal claims. United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 725 (1966); 28 U.S.C. § 1367.
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Section 1367(a) does not permit supplemental jurisdiction over a state-law claim that lacks a common nucleus of operative fact with the federal claims.

Jurgens v. Columbia County · filed 2023-10-04(a)

This Court finds that the state wrongful death claim alleged against the Providence Defendants does not arise from the same nucleus of operative fact as the remaining federal claims.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Fejerang v. G. T. L. · filed 2023-10-10(a)

Where a district court has original jurisdiction over a civil action such as a § 1983 claim, it also has supplemental jurisdiction over related state law claims pursuant to 28 U.S.C. § 1367(a), so long as the state claims “derive from a common nucleus of operative fact” with the original federal claims.
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Section 1367(a) requires state law counterclaims to share a common nucleus of operative fact with a federal claim for supplemental jurisdiction to exist.

Ji v. New Aily Foot Relax Station Inc · filed 2023-10-13(a)

Accordingly, the state law counterclaims do not arise from a common nucleus of operative fact with plaintiff's FLSA overtime claim, and must be dismissed for lack of subject matter jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state law claims that derive from the same facts as claims within the court’s original jurisdiction.

Braden v. City of Marion Illinois · filed 2023-11-07(a)

As Plaintiff’s allegations of negligence, assault and battery, and infliction of emotional distress all derive from the same facts as his Fourteenth Amendment claims, the Court will exercise supplemental jurisdiction over the state law claims.
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Section 1367(a) requires state and federal claims to share a common nucleus of operative fact; claims involving different acts, people, and times with little overlap do not qualify.

Krystyn v. University of Chicago Medical Center · filed 2023-11-27(a)

The court therefore cannot discern a “common nucleus of operative fact” among these claims upon which supplemental jurisdiction may hang its hat.
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Section 1367(a) does not provide supplemental jurisdiction over state law claims tied to the same product as federal claims when the claims arise from distinct practices and lack a common nucleus of operative fact.

Sparkman v. Comerica Bank · filed 2023-12-21(a)

Accordingly, the court lacks supplemental jurisdiction over Sparkman’s IVR claims 4 and 8.
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Section 1367(a) permits supplemental jurisdiction over state claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Lodos v. Empire Towing Corp. · filed 2024-01-09(a)

Because the Colorado Wage Act claims share a “common nucleus of operative fact” with the FLSA claims, see Wolford, 608 F.3d at 702-03, the Court will exercise supplemental jurisdiction over these claims in its discretion.
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Section 1367(a) gives supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with federal claims.

Tahchawwickah v. Brennon · filed 2024-02-12(a)

Counts I, II, and IX derive from a common nucleus of operative fact, so this Court has supplemental jurisdiction over Count IX under 28 U.S.C. § 1367.
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Section 1367(a) permits supplemental jurisdiction over a state-law counterclaim that shares a common nucleus of operative fact with federal claims.

WADE v. JMJ ENTERPRISES, LLC · filed 2024-02-13(a)

Defendants’ state law breach of contract counterclaim and Plaintiff’s claims under the FLSA are related to and derived from a common nucleus of operative facts. To promote judicial economy, the Court exercises supplemental jurisdiction over this claim.
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Section 1367(a) permits supplemental jurisdiction over state law claims when they and claims within original jurisdiction derive from a common nucleus of operative fact.

Integra Mission Critical LLC v. Cummings Electrical LP · filed 2024-02-15(a)

Defendant fails to provide sufficient information for the court to reasonably conclude that the state law claims and declaratory judgment action “derive from a common nucleus of operative fact.” Accordingly, the court lacks supplemental jurisdiction over Plaintiff’s state law claims and two of Defendant’s counterclaims.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with federal claims.

Besso v. KeyCityCapital LLC · filed 2024-02-28(a)

The Court finds that Besso’s defamation claim shares a common nucleus of operative fact with his two discrimination claims under the ADA and ADEA.
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Section 1367(a) permits supplemental jurisdiction over a state records claim when the alleged refusal to produce records is part of the same retaliation alleged in the federal claims.

Posey v. Atlanta Public Schools · filed 2024-03-21(a)

A court has supplemental jurisdictional over state claims that are “so related to [federal] claims in the action . . . that they form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. § 1367(a). Claims are sufficiently related if they “derive from a common nucleus of operative fact.” City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156, 165 (1997). Plaintiffs’ claims satisfy this test because they each arise from Defendants’ alleged discrimination, Plaintiffs’ complaints, and Defendants’ alleged retaliation for those complaints. Indeed, the complaint specifically says APS refused to respond to Plaintiffs’ ORA requests in retaliation for Plaintiffs’ protected activity. (Dkt. 4 ¶¶ 68, 78.) Plaintiffs’ federal claims seek relief for that retaliation. And so does Plaintiffs’ ORA claim.
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Section 1367(a) permits supplemental jurisdiction over a state law claim that shares a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Brain and Spine Surgery, P.C. v. International Union of Operating Engineers Local 137 Welfare Fund · filed 2024-04-10(a)

Further, to have supplemental jurisdiction over the state claim, both the federal and state claims must stem from the same “common nucleus of operative fact.”
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Section 1367(a) permits supplemental jurisdiction over a state law claim that shares a common nucleus of operative fact with remaining federal claims.

Cadiente v. City and County of Honolulu · filed 2024-04-19(a)

One final point bears mention: as the complaint correctly alleges, ECF No. 20, at PageID.223 (¶ 3), the Court has supplemental jurisdiction over this state law claim.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Cabrera v. Freedom Mortgage Corp · filed 2024-04-25(a)

Meanwhile, Plaintiff’s state-law claims stem from the same “common nucleus of operative fact” in that they also concern Freedom Mortgage’s loan to Plaintiff. ... Defendants do not explain why the Court lacks supplemental jurisdiction over these claims, and the Court concludes that it does.
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Section 1367(a) requires state law claims to share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

CANTRELL v. BRUNSWICK MAINE POLICE · filed 2024-04-29(a)

“To satisfy this standard, claims must derive from a common nucleus of operative fact with the claim satisfying original jurisdiction.” Id. (internal quotation marks omitted). Here, Cantrell’s FOAA-based claims are unrelated to the substantive Section 1983 claims that bring his case under federal jurisdiction. Accordingly, the FOAA claims are dismissed without prejudice.
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Section 1367(a) provides supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with claims within the district court’s original jurisdiction.

Stone v. The Board of County Commissioners for the County of Quay · filed 2024-05-01(a)

Thus, the Court finds that the general rule of § 1367 applies here, and supplemental jurisdiction is proper over all of Plaintiffs’ state law claims.
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Section 1367(a) does not extend supplemental jurisdiction to a permissive state-law counterclaim that lacks a common nucleus of operative fact with the federal claim.

Berry v. City of New York · filed 2024-05-01(a)

Because the claims do not substantially overlap, they share no common nucleus of operative fact and the permissive counterclaim must be dismissed.
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Section 1367(a) does not provide supplemental jurisdiction over permissive counterclaims that share only an employment relationship with federal wage claims and lack a common nucleus of operative fact.

Cicek v. Green Station Auto Services Inc. · filed 2024-05-17(a)

The Court will not exercise supplemental jurisdiction over Defendants’ permissive counterclaims for breach of the faithless servant doctrine and tortious interference with business relations because they do not share a common nucleus of operative fact with Cicek’s FLSA and NYLL claims.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim against an additional party when it shares a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Ondrasik v. Palmerton Community Ambulance · filed 2024-05-30(a)

The two claims share a common nucleus o operative facts and are so related as to form part of the same case or controversy. Thus, supplemental jurisdiction over the assault and battery claim against Defendant Correa is appropriate.
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Section 1367 permits supplemental jurisdiction only when state law claims share a common nucleus of operative fact with the federal claims.

Marin v. Carroll · filed 2024-06-11(a)

Without opining on whether these claims validly state a claim, the Court declines to exercise supplemental jurisdiction over Plaintiff’s state law claims because they do not arise from the same set of facts as alleged in Plaintiff’s federal claims.
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Section 1367(a) gives a federal court supplemental jurisdiction over state-law claims that arise from the same common nucleus of operative fact as the federal claims.

Floyd v. Saber Fitness Hegenberger, LLC · filed 2024-06-11(a)

The events giving rise to Floyd’s claims all “occurred at the Planet Fitness gyms located in the Bay Area, CA” and concern his gym membership. ... Accordingly, they all arise out of a common nucleus of operative fact.
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Section 1367(a) requires a common nucleus of operative fact between federal and state claims; a causal chain connecting their underlying events alone does not establish supplemental jurisdiction.

Cheng v. Wong · filed 2024-06-12(a)

Here, disputes over plaintiffs’ wages may have started a chain of events that eventually led to disputes over Ms. Wong’s management of the LLC, but that does not mean that resolving Ms. Cheng’s FLSA claim requires resolving plaintiffs’ derivative claims or otherwise engaging with the facts underlying those claims.
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Section 1367(a) gives a federal court supplemental jurisdiction over a state negligence claim based on the same facts as an Eighth Amendment claim.

Murphy v. Hughes · filed 2024-06-26(a)

Plaintiff’s negligence claim is based on the same facts that support the Eighth Amendment claim in Count 1. Therefore, the Court has supplemental jurisdiction to consider the claim of negligence.
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Section 1367 permits supplemental jurisdiction over state-law claims that arise from a common nucleus of operative fact with a substantial federal claim.

Brown v. Officer Robert Hooks · filed 2024-07-18(a)

The medical-malpractice claims therefore arose from “a common nucleus of operative fact with a substantial federal claim,” and the district court had supple- mental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Henry v. Nations · filed 2024-08-06(a)

Accordingly, because the claims of Plaintiff Gamberella concern the same “core factual issue” as the other Plaintiffs, that is, Defendants malpractice as it relates to the filing of subsistence claims, they are “sufficiently related for purposes of § 1367(a).”
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Section 1367(a) does not provide supplemental jurisdiction over state law counterclaims that share only an employment relationship with an FLSA wage claim.

Graham v. Green Companies Development Group, Inc. · filed 2024-08-21(a)

The counterclaims do not arise out of the same nucleus of operative facts or arise out of the same transaction or occurrence as Plaintiff’s underlying claim. Exercising supplemental jurisdiction over Defendant’s counterclaims would also delay and subvert the process of adjudicating Plaintiff’s underlying claim. The Court declines to exercise subject matter jurisdiction over Defendant’s counterclaims.
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Section 1367(a) permits supplemental jurisdiction over a contract counterclaim when its facts and evidence overlap with a federal claim.

Abiomed, Inc. v. Enmodes GmbH · filed 2024-08-23(a)

Accordingly, the Court has supplemental jurisdiction over Counterclaim Count I and will exercise it (particularly where the Court finds that there is no basis to decline to do so under § 1367(c)) and, accordingly, denies Abiomed’s motion to dismiss on this basis.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with federal claims.

Coleman v. Superintendent, Mid-State Correctional Facility · filed 2024-09-04(a)

"[F]ederal courts [may] hear and decide state-law claims along with federal-law claims when they are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy." Wisconsin Dep't. of Corr. v. Schacht, 524 U.S. 381, 387 (1998); 28 U.S.C. § 1367(a). ... Thus, there is a common nucleus between the federal and state law claims.
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Section 1367(a) does not extend supplemental jurisdiction to a disability discrimination claim that has no factual overlap with the federal unpaid overtime claims.

De la Cruz v. A.T.N. Incorporated · filed 2024-09-25(a)

The Court acknowledges Plaintiff’s concerns, but they do not justify the exercise of supplemental jurisdiction over disability discrimination claims unrelated to those conferring subject matter jurisdiction – Plaintiff’s claims of unpaid overtime.
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Section 1367(a) permits supplemental jurisdiction over state claims that share a common nucleus of operative fact with federal claims.

(PS) Gifford v. Hanson · filed 2024-09-27(a)

Having considered the facts underlying each claims, the Court finds that the state and federal claims clearly do not involve a common nucleus of operative fact.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Clee, III v. Benson Industries, Inc. · filed 2024-09-30(a)

The court therefore finds that the claims derive from a “common nucleus of operative fact” and that this court has supplemental jurisdiction over plaintiff’s remaining claims.
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Section 1367(a) does not provide supplemental jurisdiction over a state-law claim that lacks a common nucleus of operative fact with the federal claims.

Onfroy v. The Law Offices of Geoffrey T. Mott, P.C. · filed 2024-09-30(a)

That claim, however, lacks a common nucleus of operative fact with the federal claims at issue. 28 U.S.C. § 1367(a); see Achtman v. Kirby, McInerny & Squire, LLP, 464 F.3d 328, 335 (2d Cir. 2006). It is therefore dismissed (without prejudice) for lack of jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Sillas v. Meyers · filed 2024-10-03(a)

Where a district court has original jurisdiction over a civil action such as a Section 1983 claim, it also has supplemental jurisdiction over related state law claims pursuant to 28 U.S.C. § 1367(a), so long as the state claims “derive from a common nucleus of operative fact with the original federal claims.” Wisconsin v. Ho-Chunk Nation, 512 F.3d 921, 936 (7th Cir. 2008). ... As to Sillas’s claim for intentional infliction of emotional distress, the state law claim derives from the same facts as his deliberate indifference claim.
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Section 1367(a) provides supplemental jurisdiction over state law claims against different defendants when they share a common nucleus of operative fact with the federal claims.

Fei Fei Fan v. Jiang · filed 2024-12-05(a)

Fan’s claims against Jiang share a “a common nucleus of operative fact[s]” with her state law claims against Wu. See Notrica v. Bd. of Supervisors, 925 F.2d 1211, 1213 (9th Cir. 1991) (quoting United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 725 (1966)). The district court therefore had supplemental jurisdiction over both sets of claims, see 28 U.S.C. § 1367(a), and the discretion to address the claims against Wu on the merits, see Acri v. Varian Assocs., 114 F.3d 999, 1000–01 (9th Cir. 1997).
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with claims within the court’s original jurisdiction.

Choi v. SD Tools, Inc · filed 2024-12-05(a)

The court also finds it appropriate to retain supplemental jurisdiction over Choi’s NYLL claims. ... For a claim to fall within the scope of a court's supplemental jurisdiction, it must be “so related to claims in the action within such original jurisdiction that they form part of the same case or controversy.” 28 U.S.C. § 1367(a). ... Choi’s claims relate to the same common nucleus of operative fact as the other Plaintiff’s FLSA claims.
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Section 1367(a) requires a state law claim to share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

DAMIANA ROSARIO AS ADMINISTRATRIX FOR THE ESTATE OF JOSEFINA BENITEZ, ZION BRERETON, ALICIA LEARMONT, JAMES CHOI AND AND · filed 2024-12-17(a)

The Court sets forth the legal standards governing the exercise of supplemental jurisdiction over state law claims and finds that there is no common nucleus of operative fact between Plaintiff Learmont’s state claim and the remaining federal claims.
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Section 1367(a) allows a court to retain supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a dismissed federal claim.

Jackson v. LinkedIn Corporation · filed 2025-01-03(a)

The Court nonetheless retains supplemental jurisdiction over her state law claim under 28 U.S.C. § 1367(a) because the “state and federal claims … derive from a common nucleus of operative fact.”
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Section 1367(a) permits supplemental jurisdiction over a state law counterclaim when it shares a common nucleus of operative fact with a claim under the court’s original jurisdiction.

Pablo v. Buell · filed 2025-01-17(a)

Accordingly, the proper analysis for supplemental jurisdiction is whether the Pepita defendants' counterclaims are part of the same case or controversy, i.e., share a common nucleus of operative fact, as plaintiffs' federal claim.
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Section 1367(a) does not confer supplemental jurisdiction over a state-law claim that lacks a common nucleus of operative fact with the federal claims.

Hayes v. Berthelot · filed 2025-01-27(a)

Hayes alleges only a state-law public records claim against the DA Defendants, which does not share a common nucleus of operative fact with the federal claims.
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Section 1367(a) requires claims to share a common nucleus of operative fact; a connection to the same general project is insufficient when the claims involve different rights, interests, and underlying facts.

Pinnacle Madison Avenue Corporation v. Italian Trade Agency (ITA) · filed 2025-02-03(a)

Although the Petition and counterclaims both arise from the Project generally, they involve different rights, interests, and underlying facts. The Section 881 legal standard, under which the Court must balance the competing interests surrounding the Petition, is different from the negligence standard underlying ITA’s counterclaims, which would require the Court to analyze, among other factors, whether Pinnacle owed a duty of care to ITA and whether it breached that duty in providing information to the LPC, the Committee, and the DOB.
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Section 1367 permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with a federal claim and would ordinarily be tried in one proceeding.

Forbush v. NTI-CA Inc. · filed 2025-02-05

In addition, the Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over Plaintiff’s remaining state law claims because all of Plaintiff’s claims derive from a common nucleus of operative fact and are such that a plaintiff would ordinarily be expected to try them in one judicial proceeding.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with claims under the court’s original jurisdiction.

Pena v. Illinois Department of Corrections · filed 2025-02-14(a)

Where a district court has original jurisdiction over a § 1983 claim, it also has supplemental jurisdiction over related state law claims pursuant to 28 U.S.C. § 1367(a), so long as the state claims “derive from a common nucleus of operative fact” with the original federal claims.
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Section 1367(a) requires supplemental claims to share a common nucleus of operative fact with claims within the court’s original jurisdiction; shared background facts or parties alone are insufficient.

Burgh Investments, Inc. v. Burk · filed 2025-02-26(a)

The question that courts must consider when analyzing jurisdiction pursuant to 28 U.S.C. § 1367(a) is whether the supplemental claims are so related to the original claims that they form part of the same case or controversy such that one would expect the claims to be tried in a single judicial proceeding, or in other words, that they “derive from a common nucleus of operative fact.” ... Biff Burk has failed to demonstrate a common nucleus of operative facts between the claims alleged in the original complaint and his claims against the Billy Burk affiliates and Sarah Lazaro.
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Section 1367(a) permits supplemental jurisdiction when a state claim and a federal claim arise from a common nucleus of operative fact, even when the events underlying them are months apart.

Davis v. Chatham Area Transit Authority · filed 2025-03-03(a)

Accordingly, the Court attributes little importance to the six-month gap between the events of Plaintiff’s state claim and the events of her federal claim. Because the claims arise from the same common nucleus of operative fact, the Court has supplemental jurisdiction over Plaintiff’s negligence claim.
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Section 1367(a) permits supplemental jurisdiction over state law claims that derive from the same common nucleus of operative fact as the federal claims.

Imposter Pastor Movie, LLC v. Oliver · filed 2025-03-14(a)

The court exercises supplemental subject-matter jurisdiction over Plaintiff's North Carolina common law tort claims because they are “derive[d] from [the same] common nucleus of operative fact” as Plaintiff’s federal claims.
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Section 1367(a) requires a state-law claim to share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Brooks v. Kahrs · filed 2025-03-20(a)

The Court’s independent examination confirms that it lacks supplemental jurisdiction over the Louisiana Public Records Act claim.
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Section 1367 does not confer supplemental jurisdiction over state law claims that do not arise from the same nucleus of operative fact as the surviving federal claim.

Jones v. Saugahatchee Country Club (MAG+) · filed 2025-03-25(a)

Additionally, the Court finds that it lacks supplemental jurisdiction over Jones’ state law claims pursuant to 28 U.S.C. § 1367 because they do not arise out of the same nucleus of operative fact as Jones’ 42 U.S.C. § 1981 disparate treatment claim, the sole federal claim which survives dismissal.
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Section 1367(a) gives a district court supplemental jurisdiction over state law claims that share a common nucleus of operative fact with federal claims.

Muhammad v. Gap Inc. · filed 2025-03-28(a)

Plaintiffs claims against Defendants are so related to the ERISA claims that they form part of the same case or controversy because the derive from a common nucleus of operative fact.
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Section 1367 permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a substantial federal claim.

Johnson v. Raven Wood Homeowners Association · filed 2025-04-04(a)

Therefore, the Court finds the FHA cause of action arises from a different nucleus of operative facts, and the Court lacks supplemental jurisdiction over Claims II through IV, and Claim VI.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a federal claim.

O'Neill v. California Physicians' Service · filed 2025-04-11(a)

Because Plaintiff’s nonfederal causes of action form the basis for the alleged RICO conspiracy, the state law claims “derive from a common nucleus of operative fact” as her RICO claim. ... So, the Court retains supplemental jurisdiction over Plaintiff’s state law claims.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with federal claims.

Wilson v. Mid-Hudson Forensic Psychiatric Center · filed 2025-05-05(a)

Given the “common nucleus of operative fact” between the federal and NYSHRL claims present here, I choose to exercise supplemental jurisdiction over the state law claims.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Liu v. Sealy Inc. · filed 2025-05-09(a)

The Court finds that all of the Plaintiffs’ remaining claims derive from the same common nucleus of operative fact and will therefore exercise supplemental jurisdiction over those claims.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Liu v. Sealy, Inc. · filed 2025-05-09(a)

The Court finds that the remaining predicate labor violation claims derive from the same common nucleus of operative fact as Plaintiffs’ unpaid overtime allegation. As such, the Court will exercise supplemental jurisdiction over the entire PAGA action.
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Section 1367(a) permits supplemental jurisdiction when a claim shares a common nucleus of operative fact with a claim under the court’s original jurisdiction.

Springhill Avenue United Methodist Church, Inc. v. Lloyd's of London · filed 2025-05-22(a)

Here, the federal-question claim and the claims against Lloyd’s share a common nucleus of operative fact—the damage to Plaintiff’s roof.
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Section 1367(a) does not provide supplemental jurisdiction when state and federal claims relate only through a broader dispute.

GOLO, LLC v. Amazon.com, Inc. · filed 2025-06-05(a)

At best, it can be said that the “state law claims [here] only ‘relate generally’ to [the] federal claims through a broader dispute.” Philips, 2023 WL 5650621, at *2 (citation omitted). Supplemental jurisdiction does not lie in such cases.
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Section 1367(a) permits supplemental jurisdiction over a claim arising from the same nucleus of operative fact as claims within the court’s original jurisdiction.

Red Hat, Inc. v. Competitive Access Systems, Inc. · filed 2025-06-12(a)

As for Red Hat’s APAA claim, it arises from the same “nucleus of operative fact” as Red Hat’s declaratory judgment claims. ... And the court has supplemental jurisdiction over Red Hat’s APAA claim.
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Section 1367 permits supplemental jurisdiction over state law claims that arise from a common nucleus of operative fact with federal claims.

Valmont Industries, Inc. v. Rebequi · filed 2025-06-16(a)

The Court has jurisdiction over Valmont’s state law claims under 28 U.S.C. § 1367 because they arise “from a common nucleus of operative fact”—Rebequi’s post- employment business activities.
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Section 1367(a) does not provide supplemental jurisdiction when an employment retaliation claim and a later legal malpractice claim concern different operative facts.

Randolph v. Bath & Body Works, Inc. · filed 2025-06-18(a)

Whether Bath & Body Works fired Plaintiff in retaliation for him requesting an accommodation for his disability and whether Plaintiff's lawyers subsequently settled his disability discrimination charge without his consent concern different operative facts. ... Accordingly, the Court DISMISSES WITHOUT PREJUDICE Plaintiffs malpractice claim against Spitz Law for lack of jurisdiction.
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Section 1367(a) requires a state law claim to share a common nucleus of operative fact with a federal claim for supplemental jurisdiction to exist.

Bergeron v. La Porte County · filed 2025-06-18(a)

No common nucleus of operative facts exists to sustain supplemental jurisdiction over Mr. Stevens’s defamation or tortious interference claims, so the court dismisses them (counts 3 and 9) accordingly.
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Section 1367(a) does not provide supplemental jurisdiction when federal and state employment claims share only background facts about the employment relationship, rather than operative facts.

Junius Joyner, III v. Morrison and Foerster LLP · filed 2025-06-20(a)

The only facts in common between the federal claims and the D.C. law claim are the background facts that Joyner was employed by Hire Counsel and placed at Morrison; those are not “operative” facts in the sense the case law requires.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Padilla v. Ames Construction, Inc. · filed 2025-06-20(a)

Because this claim and Plaintiff’s preempted claims “derive from a common nucleus of operative fact,” the Court finds it may exercise supplemental jurisdiction over this claim. United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 725 (1966); 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a federal claim.

Lupin Atlantis Holdings SA v. Zeng · filed 2025-06-25(a)

Based on the foregoing, this Court finds there is diversity jurisdiction over this action and, additionally, because Lupin’s state law claims and DTSA claim arise from a common nucleus of operative fact, this Court also has supplemental jurisdiction over the state law claims.
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Section 1367(a) does not provide supplemental jurisdiction over state claims that share no common nucleus of operative fact with the federal claims.

Mombrun v. New York City Department of Housing Preservation and Developmentet al · filed 2025-06-30(a)

Because Plaintiff’s defamation and breach of contract claims rely on events that share no common nucleus of facts with Plaintiff’s federal claims, the Court finds no basis to exercise supplemental jurisdiction of the claims and must dismiss them for lack of jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state claims that share a common nucleus of operative fact with a federal claim; a shared employment relationship alone does not establish that connection.

SINGH v. BNO SERVICE STATION, LLC · filed 2025-07-10(a)

Lyon is controlling. There is no supplemental jurisdiction over the Plaintiff’s wrongful termination claims (Count V and Count VI).
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Section 1367(a) gives a district court supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with claims within its original jurisdiction.

Thompson v. PennyMac Loan Services LLC · filed 2025-07-16(a)

Here, the Court finds that those state law claims derive from a “common nucleus of operative fact,” such that the Court also has subject-matter jurisdiction over those claims.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Ayona v. Toyota Motor Sales, U.S.A., Inc. · filed 2025-07-17(a)

The Court will exercise supplemental jurisdiction over Ayona’s state law claims. Ayona relies on many identical facts in supporting her state law claims and her MMWA claim.
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Section 1367(a) permits supplemental jurisdiction over state-law counterclaims that share a common nucleus of operative fact with a federal claim within the court’s original jurisdiction.

Williams v. Insomnia Cookies, LLC · filed 2025-07-23(a)

As for the remaining counterclaims, the Court has supplemental jurisdiction under 28 U.S.C. § 1367, because they are part of the same dispute or controversy as the claim under the DTSA.
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Section 1367(a) requires state-law claims to share a common nucleus of operative fact with the federal claims for supplemental jurisdiction to apply.

Krasner Loan Co., Inc d/b/a American Loan Company v. Ferraris · filed 2025-07-31(a)

Having reviewed the Report for clear error and finding none, the Court agrees with the Magistrate Judge’s well-reasoned conclusion that Plaintiff’s claims against Ferraris do not share a common nucleus of operative fact with the federal claims and that exercising supplemental jurisdiction would not serve judicial economy.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with a federal claim.

ORTEZ v. BETA ELECTRIC ELP, LLC · filed 2025-07-31(a)

The NJWHL and NJWPL claims are premised on the same allegations of the FLSA claim, namely, Defendants’ alleged failure to compensate Plaintiffs of their overtime pay, thus the New Jersey wage and hour state law claims “derive from a common nucleus of operative fact” pursuant to 28 U.S.C. § 1367 and supplemental jurisdiction is appropriate.
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Section 1367(a) permits a court to exercise supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with federal claims.

Crafts Outlet, Inc., The v. Crafts Online Outlet, Inc, The · filed 2025-08-01(a)

Because the Colorado Consumer Protection Act claim shares a “common nucleus of operative fact” with the federal claims, see Price, 608 F.3d at 702-03, the Court will exercise supplemental jurisdiction over the claim in its discretion.
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Section 1367(a) requires an intervenor’s claim to share a common nucleus of operative fact with the original claims.

Hancock Whitney Bank v. MOF-Willows, LLC · filed 2025-08-13(a)

Here, SWBNO’s claim and Plaintiff’s claim do not derive from a common nucleus of operative fact because Plaintiff’s claim arises from the various agreements Defendant executed in connection with the loan,7 and SWBNO has not demonstrated any connection between its unpaid services claim and the loan and mortgage agreements at issue in the underlying case.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with the federal claims and would ordinarily be tried together.

Ealom v. University Circle Police Department · filed 2025-08-22(a)

After considering judicial economy, convenience, and fairness to the litigants, the Court is exercising supplemental jurisdiction over the state law claims because the claims derive from a common nucleus of operative fact, and the claims are such that they would be expected to be tried in one judicial proceeding.
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Section 1367(a) permits supplemental jurisdiction over state-law claims arising from the same nucleus of operative fact as federal claims.

Quinn v. Southern California Edison Company · filed 2025-08-22(a)

Quinn’s remaining state law claims all arise from the same nucleus of operative fact as the preempted claims—they all seek redress for SCE’s cancellation of the ESR Benefit. Accordingly, the Court exercises supplemental jurisdiction over Quinn’s remaining state law claims.
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Section 1367(a) requires a common nucleus of operative fact between federal and state claims; a shared employment relationship and overlapping time period alone are insufficient.

Vega · filed 2025-09-15(a)

A common employment relationship and a concurrence of events alleged, without further overlap in the alleged facts underlying the federal and state claims, do not constitute a common nucleus of operative fact required for supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Keate v. Wright · filed 2025-09-17(a)

Although there may be other reasons why Mr. Wright’s claims fail, the court finds that his claims derive from the same common nucleus of operative fact such that the court may appropriately exercise supplemental jurisdiction.
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Section 1367 permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with federal claims.

Corolla Pool and Spa Inc. v. Corolla Brad LLC · filed 2025-09-17(a)

The court has supplemental jurisdiction over plaintiff’s North Carolina state law claims under 28 U.S.C. § 1367, because plaintiff’s federal and state law claims “derive from a common nucleus of operative fact.” United Mine Workers v. Gibbs, 383 U.S. 715, 725 (1966).
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with federal claims, even when those claims are against different defendants.

Hi-Vac Corporation v. Coley · filed 2025-09-19(a)

Because the allegations against Curtis share a central fact pattern with the federal RICO scheme involving Daniel, the claims stem from a common nucleus of operative facts.
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Section 1367(a) permits supplemental jurisdiction over state-law counterclaims when their facts substantially overlap with those of the federal claims.

Crisis Pregnancy Services, Inc. v. Kamke · filed 2025-09-30(a)

The Court finds—at least at this stage—that it may properly exercise supplemental jurisdiction over Kamke’s counterclaims.
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Section 1367(a) gives federal courts supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with a substantial federal claim.

Hudson v. Data Mortgage, Inc. · filed 2025-10-07(a)

And supplemental jurisdiction exists over Hudson’s state law claims because they “arise out of a common nucleus of operative fact with a substantial federal claim.” Parker v. Scrap Metal Processors, Inc., 468 F.3d 733, 743 (11th Cir. 2006); see 28 U.S.C. § 1367(a).
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Section 1367(a) covers third-party indemnity and contribution claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Celis v. Sorenson Transportation Company · filed 2025-10-16(a)

A district court that has original jurisdiction over a claim also “shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy . . . .” 28 U.S.C. § 1367(a). ... Here, the third-party claims are merely for indemnification or contribution by the City for any damages arising from the alleged accident at issue in the Complaint—all the claims share a common nucleus of operative fact.
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Section 1367(a) permits supplemental jurisdiction over a successor liability claim in the same suit when it shares a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Carbajal · filed 2025-10-22(a)

Where, as here, a district court has original jurisdiction over a civil proceeding pursuant to § 1331 or §1332, it “shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. § 1367(a). ... Clearly that threshold is met here. Hayes Tax’s liability as a successor to Hayes Management is entirely dependent on Hayes Management’s liability under Title VII.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a federal claim.

Clasp v. Hassan · filed 2025-11-03(a)

The breach of contract claim shares a common nucleus of operative fact with CLASP’s federal trade secrets claim by virtue of Hassan’s alleged transfer of files from CLASP’s online storage system, as required for the exercise of jurisdiction under 28 U.S.C. § 1367(a), and Hassan’s DCHRA claim is against a diverse party, under 28 U.S.C. § 1332, since Hassan is a citizen of Maryland, Compl. ¶ 18; Answer ¶ 18, and CLASP is incorporated and has its principal place of business in the District of Columbia, Compl. ¶ 17; Answer ¶ 17, and Hassan alleges $5,000,000 in damages, well exceeding the amount-in-controversy threshold for diversity jurisdiction, Am. Countercl. at 16.
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Section 1367(a) requires claims to share a common nucleus of operative fact; claims arising from separate conduct by different agencies do not qualify.

Muniz · filed 2025-11-07(a)

Because the federal and state law claims do not derive from a common nucleus of operative fact, the Court lacks supplemental jurisdiction over the claims against the County Defendants.
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Section 1367(a) gives a federal court supplemental jurisdiction over claims that share a common nucleus of operative fact with claims within its original jurisdiction.

WILLIAMS v. SIERRA DONOR SERVICES, et al. · filed 2025-11-25(a)

The court therefore finds that the claims derive from a “common nucleus of operative fact” and that this court has supplemental jurisdiction over plaintiff’s remaining claims.
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Section 1367(a) permits supplemental jurisdiction over a state claim that shares a common nucleus of operative fact with a federal claim.

Carter · filed 2025-12-01(a)

Here, because the factual allegations supporting both the federal and state claims here are the same, the Court finds that they arise out of a common nucleus of operative fact, satisfying the “case or controversy” standard under § 1367.
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Section 1367(a) requires a discernable overlap between the operative facts of the federal and state claims for supplemental jurisdiction.

Preble · filed 2025-12-02(a)

That persuades the Court that supplemental jurisdiction is lacking over Plaintiffs’ MGDPA claim.
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Section 1367(a) permits supplemental jurisdiction over a counterclaim that shares a common nucleus of operative fact with the original claim, whether the counterclaim is compulsory or permissive.

Cordeiro · filed 2025-12-09(a)

It is not necessary for this Court to decide whether the counterclaim is compulsory or permissive in nature, because as discussed, this Court already finds that Counterclaim Plaintiffs’ counterclaim shares a common nucleus of operative fact with the original Complaint, which is sufficient to confer supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a federal claim within the court’s original jurisdiction.

Jackson v. City of Birmingham · filed 2025-12-10(a)

Because this court has subject matter jurisdiction over Plaintiff’s FMLA claims, and Plaintiff’s outrage/IIED claim shares a “common nucleus of operative fact” and thus “form[s] part of the same case or controversy” as Plaintiff’s FMLA claims, the court may exercise supplemental jurisdiction over Plaintiff’s outrage/IIED claim.
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Section 1367 permits a court to consider a state law claim arising from the same facts as a surviving federal claim.

Perez · filed 2025-12-10(a)

Because Perez’s state law medical malpractice claim arises from the same facts as his Eighth Amendment claim, I will consider whether he has alleged any plausible state law claims for medical malpractice against Nurse Doe, who is the only defendant against whom Perez is proceeding on an Eighth Amendment claim in this action.
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Section 1367 gives a district court supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a claim within its original jurisdiction.

Walsh v. Rokoko Electronics · filed 2025-12-22(a)

And because the Court has original jurisdiction over Walsh’s DMCA claim, the Court has “supplemental jurisdiction over all” of Walsh’s state law claims because they “derive from a common nucleus of operative fact.” 28 U.S.C. § 1367; City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156, 165 (1997).
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with federal claims.

XPEL, Inc. v. Dope Tintings LLC · filed 2025-12-31(a)

The Court also properly exercises supplemental jurisdiction over Plaintiff’s state-law claims, as they share a “common nucleus of operative fact” with the federal claims.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Michael Lichter Photography, LLC v. GIT Corp. · filed 2026-01-26(a)

Pursuant to 28 U.S.C. § 1367(a), the Court can exercise supplemental jurisdiction over these state law claims if they are “so related to claims in the action within such original jurisdiction that they form part of the same case or controversy.” ... The Court finds that all of the claims derive from a common nucleus of operative fact.
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Section 1367(a) permits supplemental jurisdiction over a state-law claim that shares a common nucleus of operative fact with a federal claim.

Advanced Accelerator Applications USA, Inc. v. Curium US LLC · filed 2026-02-17(a)

Plaintiffs ask this Court to exercise supplemental jurisdiction over the state law claim. (D.I. 106 at 9). See 28 U.S.C. § 1367(a). The Court will do so. The Amended Complaint is clear that both the federal and state claims at issue share a “common nucleus of operative fact” – the alleged misappropriation of confidential information learned during a business collaboration.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative fact with federal claims.

Reynolds · filed 2026-03-05(a)

The federal and state-law claims arise out of a “common nucleus of operative fact” (namely G.C.’s death and Defendants’ conduct in reporting Sylwia for child abuse), which unlocks the door to the Court’s supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state law claims that arise from a common nucleus of operative fact with a claim under the court’s original jurisdiction.

Desrochers · filed 2026-03-06(a)

Moreover, pursuant to 28 U.S.C. § 1367(a), the Court can exercise supplemental jurisdiction over plaintiff’s state law claims if they are “so related to claims in the action within such original jurisdiction that they form part of the same case or controversy.” ... Here, the Court finds that all of plaintiff’s claims arise out a common nucleus of operative fact. ... Thus, the Court will exercise supplemental jurisdiction over plaintiff’s state law claims.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that form part of the same case or controversy as federal claims because they arise from a common nucleus of operative fact.

Price v. Automotive Finance Corporation · filed 2026-03-11(a)

Further, to the extent Ms. Price is raising state-law claims, the court may exercise supplemental jurisdiction over those claims because both her federal and state claims “form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. § 1367(a). That is, Ms. Price’s claims all “derive from a ‘common nucleus of operative fact’”: the alleged garnishment of her bank account.
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Section 1367(a) covers state-law claims sharing a common nucleus of operative fact with federal claims; the claims need not share the same legal elements.

Barker · filed 2026-03-27(a)

Any claims “sharing a ‘common nucleus of operative fact’ with the federal-law ones” are covered by the Court’s supplemental jurisdiction. Royal Canin U. S. A., Inc. v. Wullschleger, 604 U.S. 22, 31 (2025). As this question “is one of fact,” id., it is irrelevant it would be unnecessary for the Barkers “to prove, as an element, the violation of those federal statutes,” Objections at 3, to prevail on the state-law claims.
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Section 1367 requires state law claims to share a common nucleus of operative fact with a federal claim for supplemental jurisdiction.

Potts · filed 2026-04-13(a)

The Court has jurisdiction under 28 U.S.C. § 1331 for Plaintiff’s claims arising under federal law, but for supplemental jurisdiction to exist over accompanying state law claims under 28 U.S.C. § 1367, the state law claims must arise from “a common nucleus of operative fact” as a federal claim.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Hiligh v. Duncan & Hopkins, P.C. · filed 2026-04-28(a)

Hiligh’s federal and D.C. law claims thus “derive from a common nucleus of operative fact,” United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 725 (1966), and “[t]hat is all [§ 1367(a)] requires to establish supplemental jurisdiction[,]” City of Chicago, 522 U.S. at 165; see also Busby v. Cap. One, N.A., 759 F. Supp. 2d 81, 85 (D.D.C. 2011) (exercising supplemental jurisdiction over state law claims because they arose out of the same facts as the plaintiff’s RICO claims).
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Section 1367(a) permits supplemental jurisdiction over counterclaims that share a common nucleus of operative fact with federal claims.

Adams v. Fort Myer Construction Corporation · filed 2026-04-30(a)

A common nucleus of fact unites Fort Myer’s counterclaims with Adams’s federal claims. All these claims turn on the reason for Adams’s firing. ... So supplemental jurisdiction exists.
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Section 1367(a) permits supplemental jurisdiction over counterclaims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Torres-Torres · filed 2026-05-22(a)

Thus, taking these considerations together, the Court finds that the Counterclaim is so related to the original claim that they consist of the same case or controversy.
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Section 1367(a) does not permit supplemental jurisdiction over a state negligence claim that shares no common nucleus of operative fact with a federal wage claim.

STEWART v. LEWIS · filed 2019-09-10(a)

Thus, the Court concludes that Ms. Stewart’s state law negligence claim against the Homeowner Defendants does not share a “common nucleus of operative fact” with her federal FLSA claim against the Amazon Defendants.
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Section 1367(a) permits supplemental jurisdiction over state-law claims against different defendants when they arise from the same common nucleus of operative fact as a federal claim.

Badgerow v. Walters · filed 2020-09-15(a)

We have held, second, that all of Badgerow’s claims against the Principals and Ameriprise in the FINRA arbitration arose from the same common nucleus of operative fact, and that under the principle of supplemental jurisdiction, federal jurisdiction obtains over Badgerow’s state-law tortious interference and whistleblower claims.
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Section 1367(a) applies the common nucleus of operative fact test to supplemental jurisdiction over a judgment recognition claim.

City of Almaty, Kazahkstan v. Ablyazov · filed 2021-03-29(a)

And so there is no serious basis for BTA’s contention that the applicability of Gibbs to its judgment recognition claim turns on whether the Court was evaluating supplemental jurisdiction under § 1367(a) or directly under the Constitution.
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Section 1367(a) permits supplemental jurisdiction over claims that share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Artra Group, Inc. v. Salomon Bros. Holding Co. (In Re Emerald Acquisition Corp.) · filed 1994-07-15(a)

While all six counts relate to Artra’s attempt to recover its investment in the LBO Transaction, Counts I through IV do not arise out of the common nucleus of operative fact as Counts V and VI. Therefore, the court denies the Defendants’ request to exercise supplemental jurisdiction to hear the LBO Transaction Claims.
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Section 1367(a) permits supplemental jurisdiction over state and federal claims that arise from a common nucleus of operative fact.

Doe v. City of Chicago · filed 1994-11-16(a)

In a case containing state and federal law claims, a district court may exercise supplemental jurisdiction over state law claims when the state claims “are so related to [the federal claims] that they form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. 1367(a). ... Plaintiffs’ IACA and federal claims arise from a common nucleus of operative fact. All claims arise from the same HTV testing. ... Accordingly, supplemental jurisdiction is appropriate.
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Section 1367(a) gives district courts supplemental jurisdiction over state claims against additional defendants when those claims share a common nucleus of operative fact with federal claims.

Krehling v. Baron · filed 1995-09-27(a)

Plaintiffs state negligence claims form part of the same case or controversy as the RICO claims because both they all arise from a common nucleus of operative fact. Accordingly, this Court has jurisdiction over Plaintiffs state law negligence claims under the broad grant of supplemental jurisdiction in 28 U.S.C. § 1367(a) and must deny Defendants’ motion to dismiss on the basis of lack of jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state claims only when they share a common nucleus of operative fact with a claim within the court’s original jurisdiction; a causal relationship alone does not suffice.

Salei v. Boardwalk Regency Corp. · filed 1996-01-23(a)

The fact that such a separate inquiry would be necessary shows that the federal and state claims do not “derive from a common nucleus of operative fact.” Accordingly, under Gibbs and its codification at 28 U.S.C. § 1367(a), Plaintiffs state claims do not lie within this Court’s supplemental jurisdiction.
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Common nucleus of operative fact — through 2021

Section 1367 permits supplemental jurisdiction over state wage claims arising from the same operative facts as federal wage claims.

Marquez v. AMRG Holdings · filed 2021-02-05(a)

Pursuant to 28 U.S.C. § 1367, ... the Court finds that it has supplemental jurisdiction over Plaintiff’s state law claims, as they arise out of the same set of operative facts, namely, Defendants’ failure to pay Plaintiff her owed wages.
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Section 1367(a) permits supplemental jurisdiction over state-law claims that share a common nucleus of operative facts with a claim within the court’s original jurisdiction.

Strojnik v. C&H Kingman LLC · filed 2021-01-05(a)

The ADA, brand deceit, civil conspiracy, and aiding and abetting claims all share a common nucleus of operative facts. The threshold requirement for supplemental jurisdiction under 28 U.S.C. § 1367(a) is satisfied.
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Section 1367 permits supplemental jurisdiction over state fraud and negligence claims arising from the same investigations as federal ADA claims.

Strojnik v. New Crescent Investments LLC · filed 2021-01-06(a)

If a claim falling under a federal court’s original jurisdiction shares a “common nucleus of operative fact” with other state law claims, the court may exercise supplemental jurisdiction over those other claims. ... Here, the Court may exercise supplemental jurisdiction over state fraud and negligence claims that relate to Defendants’ alleged federal ADA violations.
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Section 1367(a) requires state and federal claims to share a common nucleus of operative fact; a shared employment relationship alone does not establish supplemental jurisdiction.

Kubala v. Smith · filed 2021-01-07(a)

Kubala’s sexual-harassment and First Amendment claims share no operative facts because no harassment occurred during the alleged First Amendment violations. Therefore, the district court had no jurisdiction to hear Kubala’s state sexual-harassment claim.
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Section 1367(a) permits supplemental jurisdiction over counterclaims that share a common nucleus of operative fact with a claim within the court’s original jurisdiction.

Johnson v. Sun & Chang Corporation · filed 2021-01-08(a)

Because original jurisdiction here stems from a federal question, the court has supplemental jurisdiction over counterclaims “so related” to the federal claim “that they form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. § 1367(a).
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Section 1367(a) requires state and federal claims to arise from a common nucleus of operative fact for supplemental jurisdiction.

Jones v. Evangelidas · filed 2021-01-08(a)

The cases do not arise out of the same nucleus of operative fact and therefore this Court lacks subject matter jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over an added plaintiff’s state claims when the same acts underlie the federal claims and allegedly violate parallel federal and state laws.

FEDERAL TRADE COMMISSION v. AMERICAN FUTURE SYSTEMS, INC. · filed 2021-01-20(a)

Because these “same acts” allegedly violate “parallel federal and state laws, the common nucleus of operative facts is obvious” and the Court may properly exercise supplemental jurisdiction over the OAG’s proposed UTPCPL claims.
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Section 1367(a) permits supplemental jurisdiction over state law claims arising from the same operative facts as a federal claim, but not over claims based on other aspects of the dispute.

Browne v. Waldo · filed 2021-02-01(a)

Claims arising from those operative facts can support supplemental jurisdiction. Claims based on other aspects of this dispute should be dismissed.
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Section 1367(a) permits supplemental jurisdiction over state law claims that share a common nucleus of operative fact with federal claims.

Smallwood v. Delta Airlines, Inc. · filed 2021-02-09(a)

Because Smallwood’s state law disability discrimination claims share “a common nucleus of operative fact” with her federal FMLA claims, the Court may exercise its supplemental jurisdiction to decide them.
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Notes 18901–19050 of 23,839, oldest cases first.

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