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No reviewed case has held this section invalid, preempted, superseded or repealed.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.

Fraud claims and factual overlap

Section 1367(a) permits supplemental jurisdiction over state and MMWA claims arising from the same transaction as a fraud claim within diversity jurisdiction.

Barnes v. West, Inc. · filed 2003-03-10(a)

In this case, it is clear that all of plaintiffs claims arise from a single event, namely her purchase from defendant of what she believed was a new car. Accordingly, there is federal diversity jurisdiction over the fraud claim and supplemental jurisdiction over all of the remaining claims, including the MMWA claim.
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Section 1367(a) gives a district court supplemental jurisdiction over fraud claims that form part of the same case or controversy as claims within its original jurisdiction.

Lehman Bros. Inc. v. City of Lodi · filed 2004-08-20(a)

As indicated above, the court thus has supplemental jurisdiction over Lehman's tort claims for fraud as they are part of the "same case or controversy” for purposes of Section 1367.
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Section 1367 does not provide supplemental jurisdiction over a later accounting malpractice claim that is not part of the same case or controversy as the federal securities fraud claims.

Nathel v. Siegal · filed 2008-10-20(a)

The claim is based solely on the preparation of a tax return for one partnership in one tax year, after the Plaintiffs had already invested. As such, it is not part of the same case or controversy, and it would not serve the ends of judicial efficiency for the Guralnick Defendants to continue as co-defendants in the securities fraud that forms the core of Plaintiffs’ grievances.
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Section 1367(a) permits supplemental jurisdiction over a state law fraud claim closely related to a federal contribution claim when both arise from the same audit and records.

Gesualdi v. Fortunata Carting Inc. · filed 2014-03-19(a)

After consideration of the submissions, this Court recommends that this Court exercise supplemental jurisdiction over plaintiffs’ claim for common law fraud. ... The claim for recoupment of the benefits paid to Mr. Mascia is closely related to the claim for contributions owed based on the audit conducted; plaintiffs, in fact, discovered this impropriety as a result of the audit and examination of the remittance reports and payroll records.
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Related claims in ERISA suits

Section 1367 permits supplemental jurisdiction over a legal reimbursement claim that is part of the same case or controversy as an equitable ERISA claim.

Sheet Metal Workers' Local 73 Welfare Fund Board of Trustees v. DeGryse · filed 2008-04-17(a)

Here, this legal claim theory, which is incorporated in Count I, is part of the same case or controversy as the equitable claim and it is appropriate to exercise supplemental jurisdiction over it.
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Section 1367(a) permits supplemental jurisdiction over an alter ego claim intertwined with an ERISA cause of action brought in the same case.

Boland v. Fortis Construction Co. · filed 2011-07-12(a)

Courts have consistently exercised subject matter jurisdiction over ERISA claims intertwined with questions regarding alter ego liability, and this Court concludes that supplemental jurisdiction, pursuant to 28 U.S.C. § 1367, is proper here.
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Section 1367(a) permits supplemental jurisdiction over an alter ego claim intertwined with an ERISA cause of action as part of the same case or controversy.

Boland v. Fortis Construction Company, LLC · filed 2011-07-12(a)

When claims of alter ego liability are intertwined with a federal cause of action, however, the Court may assert subject matter jurisdiction over all allegations contained in a plaintiff’s Complaint, even ones not arising under federal law, pursuant to 28 U.S.C. § 1367.
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Related shipments below the Carmack threshold

Section 1367(a) gives a district court supplemental jurisdiction over shipment claims below the jurisdictional amount when they form part of the same case or controversy as shipment claims that meet it under the same agreement.

Schoenmann Produce Co. v. Burlington Northern & Santa Fe Railway Co. · filed 2006-02-24(a)

This court has supplemental jurisdiction over these claims because each shipment made pursuant to the agreement between Burlington and Schoenmann "form[s] part of the same case or controversy” as the shipments that contained at least $10,000 in goods.
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State claims against defendants facing no federal claim

Section 1367(a) permits supplemental jurisdiction over state law claims against a defendant who faces no federal claim when the state and federal claims share a common nucleus of operative fact.

Carton v. B & B EQUITIES GROUP, LLC · filed 2011-12-07(a)

But the relevant question for supplemental jurisdiction is not whether the defendant has an interest in the federal cause of action, but whether the federal and state causes of action share a common nucleus of operative fact. Here the federal and state causes of action clearly share a common nucleus of operative fact as all of the Cartons’ claims — both the federal and state law claims — arise from the illicit STOLI scheme the parties engaged in, including Diggle and the Samuel L. Diggle ILIT. Because the federal claims and the claims against Diggle all arise from the defendants participation in the STOLI arrangement, the Court has supplemental jurisdiction over the matter.
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Related claims against additional parties

Section 1367(a) permits supplemental jurisdiction over related state-law claims against additional parties even when no federal claim is asserted against them.

Alexander by Alexander v. Goldome Credit Corp. · filed 1991-07-10(a)

Nevertheless, § 1367 now allows for the exercise of pendent party jurisdiction, the absence of which previously presented a large obstacle in cases such as this one, where federal and state claims are asserted against one defendant, only state claims are alleged against other defendants, and the entire case is then removed.
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Section 1367(a) permits supplemental jurisdiction over state claims that form part of the same case or controversy as a surviving federal claim, even when the state claims involve additional parties.

Attick v. Valeria Associates, L.P. · filed 1992-03-19(a)

28 U.S.C. § 1367(a) allows supplemental jurisdiction over pendent state claims which “form part of the same ease or controversy” as the federal claims asserted, even if the state claims involve additional parties. Therefore, this court has supplemental jurisdiction over claim XIII (against the principals and FC Bank), claim XIV (against FC Bank), and claim XV (against the principals, Balbec Corp. and Questco), which are part of the same case or controversy as the RICO claim (claim III) which was sustained.
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Section 1367(a) gives a district court supplemental jurisdiction over claims against additional parties when they form part of the same case or controversy as a claim within its original jurisdiction.

Fasco Industries, Inc. v. MacK · filed 1994-01-28(a)

We do not consider whether Fasco has independent federal question jurisdiction over the claims against Continental, because we find that we have supplemental jurisdiction over such claims. ... When a plaintiff, like Fasco, alleges a single wrong arising out of an interlocking series of transactions, the claims against all of the defendants necessarily satisfy the “case of controversy” requirement.
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Section 1367 gives a federal court supplemental jurisdiction over state claims arising from the same set of operative facts as federal claims, even when the state claims are against different defendants.

Merine Ex Rel. Prudential-Bache Utility Fund, Inc. v. Prudential-Bache Utility Fund, Inc. · filed 1994-08-05(a)

Merine’s claims against the Fund and the Inside Directors clearly arise out of the same set of operative facts as do his federal claims against the other defendants under § 36(b) of the ICA. Accordingly, this Court has supplemental jurisdiction over the state claims under 28 U.S.C. § 1367 (Supp. III 1991).
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Section 1367(a) permits supplemental jurisdiction over claims against additional parties that form part of the same case or controversy as claims within the court’s admiralty jurisdiction.

Morris v. Princess Cruises, Inc. · filed 2001-01-10(a)

Appellant’s claims against the Insurers, assuming arguendo that they do not sound in admiralty, would have been properly before the court based on supplemental jurisdiction, as they form part of the same “case or controversy” involving Mrs. Morris’s claims against Princess.
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Section 1367(a) extends supplemental jurisdiction to state law claims arising from the same case or controversy as federal claims, including related claims against additional parties.

Ciambriello v. County of Nassau, Civil Service Employees Association, Inc., Russell Rinchiuso, Richard Cotugno · filed 2002-06-04(a)

As we have reinstated Ciambriello's § 1983 claim against the County and the individual defendants, however, we also reinstate Ciambriello's state law claims. All of Ciambriello's claims relate to his demotion and the procedures the County and CSEA employed — or did not employ — in effecting his demotion. 28 U.S.C. § 1367(a). The state law claims therefore "form part of the same case or controversy" as the § 1983 claims. Although we have dismissed both § 1983 claims against CSEA, the state law claims against CSEA should nonetheless survive, as "supplemental jurisdiction shall include claims that involve the joinder or intervention of additional parties." Id.
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Section 1367 permits supplemental jurisdiction over claims involving additional parties when their key factual questions are sufficiently intertwined with a matter properly before the federal court.

Peter Bay Homeowners Association, Inc. v. Stillman · filed 2002-06-27(a)

As key threshold factual questions concerning the easement necessarily revolve around the meaning of the original Harthman decision, the issues are sufficiently intertwined to be considered part of the "same case or controversy."
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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 FLSA claims, including claims involving additional parties.

Hasken v. City of Louisville · filed 2003-02-11(a)

Under 28 U.S.C. § 1367(a), we have supplemental jurisdiction over other claims that “form part of the same case or controversy under Article III of the United States Constitution,” including those that “involve the joinder or intervention of additional parties.” While the state law claims of the proposed class form a part of the same case or controversy as the FLSA claims, we may decline to exercise our supplemental jurisdiction over them if, among other things, the state law claims substantially predominate over the federal claims or there are other compelling reasons for declining jurisdiction. 28 U.S.C. § 1367(c).
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Section 1367(a) permits supplemental jurisdiction over a state claim against different defendants when it forms part of the same case or controversy as the federal claims.

Lathrop v. Juneau & Associates, Inc. P.C. · filed 2004-02-11(a)

Second, this Court has supplemental jurisdiction over the Granite City Defendants pursuant to 28 U.S.C. § 1367 since the state claim of civil conspiracy against the Granite City Defendants involves the same case or controversy as the federal claims against the Juneau Defendants.
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Section 1367(a) permits supplemental jurisdiction over state law claims against additional defendants when those claims arise from the same transaction and occurrences as the federal claims.

Kennedy v. R.W.C., Inc. · filed 2005-03-16(a)

Although the plaintiff may not maintain an action under Title VII or the ELCRA against the individual defendants, there is no bar against proceeding against them on the other counts of the complaint, since those claims arise from the transaction and occurrences giving rise to the federal actions against R.W.C., Inc.
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Section 1367(a) permits supplemental jurisdiction over state-law claims against an additional party when those claims share a common nucleus of operative fact with viable federal claims against another party.

Vidal v. Health South Rehabilitation Hospital · filed 2006-07-31(a)

Therefore, since the parties agree that the federal claims are amenable to relief as to defendant Health South, and inasmuch as all claims by plaintiff derive from the same set of facts, the Court shall exercise its supplemental jurisdiction over the state law claims that remain viable against defendant Sueiro.
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Section 1367 permits jurisdiction over related state law claims against a party lacking an independent basis for federal jurisdiction when federal claims against other defendants remain pending.

Rossi-Cortes v. Toledo-Rivera · filed 2008-03-26

The doctrine of pendent jurisdiction allows federal courts to exercise jurisdiction over a party, not otherwise subject to federal jurisdiction, if the state claims against this party are related to federal claims properly asserted against other defendants in the case. ... Because Plaintiffs’ claims against Conga’s Bar are related to the federal claims that remain pending before the Court, the Court DENIES Defendant Conga’s Bar’s motion to dismiss on jurisdictional grounds.
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Section 1367(a) gives a district court supplemental jurisdiction over claims against additional defendants that arise from the same facts as a claim within its original jurisdiction, regardless of the related claims’ eventual merits.

ABF Freight System, Inc. v. International Brotherhood of Teamsters · filed 2011-07-06(a)

Having original jurisdiction over ABF’s 301(a) action against the Union, the district court had supplemental jurisdiction over ABF’s claims against YRC (regardless of their eventual merit), as the claims against all defendants arose from the same facts.
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Section 1367(a) permits supplemental jurisdiction over related state-law claims against additional parties when federal claims against other defendants remain pending.

Garay v. Liriano · filed 2012-03-16(a)

This ignores the fact that Plaintiffs’ § 1983 claims are still proceeding against the District and the police officers. The Court thus may exercise supplemental jurisdiction, formerly known as pendent jurisdiction, over the remaining common-law claims against Wilson and Van Metre.
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Section 1367(a) gives a federal court supplemental jurisdiction over related tort claims against an airline employee that invoke the Montreal Convention’s Article 30 proviso.

Fadhliah v. Société Air France · filed 2013-10-01(a)

To the extent that Plaintiffs assault, battery, and intentional-infliction-of-emotional-distress claims invoke Article 30’s proviso, the Court has supplemental jurisdiction over those claims under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state law claims against a party even after its federal claim is dismissed, if the state claims form the same case or controversy as pending federal claims against another party.

Bryant v. Steele · filed 2014-06-03(a)

In the present matter, the state law claims against Brunswick are so closely related to the pending federal claims— including, the Section 1983 Fourth Amendment claim against Steele- — that they form the same case or controversy. Accordingly, the Court denies Brunswick’s motion to dismiss the pendent state law claims against it.
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Section 1367(a) permits supplemental jurisdiction over related state law claims against an individual defendant when federal claims against another defendant remain pending in the same case.

Noia v. Orthopedic Associates · filed 2015-02-09(a)

Here, the proposed state law claims against Dr. Puopolo are so related and, in light of the fact that this case will proceed in this Court with respect to the Defendant, there is good reason, including judicial economy, to exercise supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over related state law claims against an additional party even when the court lacks original jurisdiction over that party.

McFadden v. Washington Metropolitan Area Transit Authority · filed 2016-03-07(a)

Here, the only rebuff from Dr. Herzberg concerning the propriety of the Court exercising supplemental jurisdiction is that the Court does not “already [have] original jurisdiction” over him and so there is no jurisdiction to supplement. Hertzberg Opp’n to Leave Mot. at 6 (emphasis added). But a close reading of the supplemental jurisdiction statute makes clear that this is no basis for the Court to refrain from exercising supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state-law claims against one defendant when federal claims remain against other defendants, even if the federal claims against that defendant are dismissed.

Haber Land Co. v. Am. Steel City Indus. Leasing, Inc. · filed 2019-05-03(a)

Unless Haber's federal-law claims were dismissed as against all Defendants, supplemental jurisdiction over the state-law claims against Caterpillar would remain appropriate under the supplemental jurisdiction statute.
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Section 1367(a) permits supplemental jurisdiction over related state law claims against a party who is not named in the federal claim when the claims form part of the same case or controversy.

Ozone Solutions, Inc v. Rozeboom · filed 2019-08-19(a)

I agree with Ozone that based on the allegations in its complaint, its claims against Rozeboom “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). Because I have found that Count I establishes subject matter jurisdiction and should not be dismissed, this court has supplemental jurisdiction over the state law claims against both Hoekstra and Rozeboom.
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Section 1367(a) permits supplemental jurisdiction over state law claims against a defendant whose federal claim has been dismissed when federal claims against other defendants remain and the claims arise from the same case or controversy.

Farnsworth v. Flagstaff, City of · filed 2020-02-03(a)

Although the Court has dismissed Plaintiffs’ § 1983 claim, the Court may still hear ... Plaintiffs’ state law claims pursuant to 28 U.S.C. § 1367(a). ... Therefore, the Court has ... supplemental jurisdiction over the state law claims Plaintiffs assert against Defendant ... Flagstaff.
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Section 1367(a) permits supplemental jurisdiction over counterclaims against an additional party when they share evidence, parties, and events with claims within the court’s original jurisdiction.

Maas v. Zymbe, LLC · filed 2020-06-17(a)

Thus, exercising supplemental jurisdiction over the counterclaims against Mr. Leaf is proper under 28 U.S.C. § 1367 because adjudicating the underlying action will involve consideration of some of the same evidence, parties, and events at issue in the cross-complaint.
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Section 1367(a) permits supplemental jurisdiction over state law claims against additional parties when those claims share a common nucleus of operative fact with federal claims.

Zap Cellular, Inc. v. Weintraub · filed 2022-09-19(a)

Here, Plaintiff’s state law claims against M. Weintraub, Dresdner, Weinstock, and Mazal all “derive from a common nucleus of operative fact” with the federal claims.
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Section 1367(a) permits a related state-law claim against an additional defendant who faces no federal claim when common causation issues connect that claim to the federal claims.

Miller v. Winner · filed 2022-11-01(a)

Second, Miller need not state a federal claim against Salmonsen if he states a federal claim against other defendants and his claim against Salmonsen is “so related to the claims in the action within such original jurisdiction that they form part of the same case or controversy.”
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Related counterclaims as one controversy

Section 1367 permits supplemental jurisdiction over a debt-collection counterclaim sharing a common nucleus of operative facts with an FCRA accuracy claim when the counterclaim does not substantially predominate and judicial economy favors joint adjudication.

Cowley v. Equifax Information Services, LLC · filed 2019-10-21(a), (c)(2)

The same facts underlying UFCSC’s breach of contract claim, thus, apply in determining the accuracy of Plaintiff’s claim under § 1681s-2(b). So UCFSC’s counter claim arises from a common nucleus of operative facts as Plaintiff’s FCRA claims. ... Here, the interest of judicial economy warrants exercising supplemental jurisdiction. ... While it is true that attempts to reconcile federal and state law could dominate and complicate pretrial practice and trial, the Court does not see how a simple breach of contract claim for collection of a debt could substantially predominate over Plaintiff’s FCRA claim.
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Section 1367(a) permits supplemental jurisdiction over state-law counterclaims that form part of the same case or controversy as federal claims or federal counterclaims.

Polaris Pool Systems v. Letro Products, Inc. · filed 1995-03-13(a)

Thus, the state-law counterclaims “form part of the same case or controversy” as either (or both) Polaris’ federal claims and Letro’s federal counterclaims. This is sufficient to confer supplemental jurisdiction under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over counterclaims against additional parties when the claims derive from a common nucleus of operative facts with claims within the court’s original jurisdiction.

Travelers Insurance v. Intraco, Inc. · filed 1995-10-10(a)

It follows from the Court’s discussion of the related Rule 20(a) issue, that defendants’ claims against Travelers and the Brown defendants derive in substantial part from a common nucleus of operative facts and are the type of claims which ought to be tried in one action. ... As the joinder of the Brown defendants is permissible under Rule 20(a) and the Court has supplemental jurisdiction under Section 1367(a), the motion to amend counterclaim and add defendants is granted.
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Section 1367(a) permits supplemental jurisdiction over an intervenor’s state-law counterclaim in an admiralty action when the claims derive from a common nucleus of operative fact.

Crosby Yacht Yard, Inc. v. Yacht "Chardonnay" · filed 1996-01-11(a)

Title 28 U.S.C. § 1367 confers jurisdiction because Crosby’s and Bornstein’s claims “derive from a common nucleus of operative fact.”
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Section 1367(a) requires a state-law counterclaim to be so logically intertwined with the federal claim that a court cannot reasonably decide one without the other; one common issue of law or fact is insufficient.

Allen v. Leal · filed 1998-11-05(a)

In other words, the counterclaim must be so logically intertwined with the plaintiffs’ claim that a court cannot reasonably determine one without the other. A single common issue of law or fact is not enough for supplemental jurisdiction.
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Section 1367(a) gives district courts supplemental jurisdiction over counterclaims that are sufficiently related to the original claims to form the same Article III case or controversy.

Gross v. Weingarten · filed 2000-06-30(a)

In addition to having diversity jurisdiction, the district court had supplemental jurisdiction under 28 U.S.C. § 1367(a) because the counterclaims are so related to the deputy receiver's claims that they form part of the same Article III case or controversy.
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Section 1367 provides supplemental jurisdiction over a matter sufficiently related to the other claims and counterclaims to form part of the same case or controversy.

Haymond v. Lundy · filed 2001-08-31(a)

The court has supplemental jurisdiction over this matter under 28 U.S.C. § 1367; the court found this matter sufficiently related to the other claims of Haymond and counterclaims of Lundy that they formed part of the same case and controversy.
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Section 1367(a) permits supplemental jurisdiction over counterclaims that share a factual nexus with claims within the court’s original jurisdiction.

Carabillo v. Ullico, Inc. · filed 2004-09-30(a)

Although the Court does not believe that these counterclaims can be asserted under “federal common law,” the Court does find that there is a factual nexus between Carabillo’s ERISA claim and ULLICO’s counterclaims that benefits cannot be paid under the Auxiliary and Deferred Compensation Plans because such plans were improperly established, amended, or implemented.
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Section 1367(a) permits supplemental jurisdiction over a foreclosure counterclaim when it shares the parties, property, and central foreclosure question with claims under the court’s original jurisdiction.

Molina v. Onewest Bank, FSH · filed 2012-09-30(a)

The Court has jurisdiction over OneWest’s Counterclaim Complaint under 28 U.S.C. § 1367, which states in pertinent part: ... The Counterclaim Complaint involves the same parties, the same Property, and the overlapping question as to OneWest’s right to foreclose on the Property.
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Claims concerning separate agency decisions

Section 1367(a) permits supplemental jurisdiction over state claims that share a common nucleus of operative fact with federal claims, even when the claims concern different agency decisions at different times.

Communities for a Better Environment v. Cenco Refining Co. · filed 2001-06-22(a)

Based on the factual and legal interrelation of the claims, the Court declines to dismiss CBE’s supplemental claims under § 1367. ... Plaintiffs allegations demonstrate a common nucleus of operative fact.
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Related securities claims

Section 1367 permits supplemental jurisdiction over a state law shareholder derivative claim arising from the same facts as federal securities claims.

In Re Dpl Inc., Securities Litigation · filed 2003-08-04(a)

The basis upon which these motions are grounded is the Defendants’ contention that the shareholder derivative claim arises out of the same facts as the Plaintiffs’ federal securities law claims, and, as a result, this Court can exercise supplemental jurisdiction over the shareholder derivative claim, pursuant to 28 U.S.C. § 1367. With those premises, this Court cannot disagree.
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Section 1367(a) gives a federal court supplemental jurisdiction over state law claims based on the same facts as federal claims when they form part of the same case or controversy.

In Re Storage Technology Corporation Securities Litigation · filed 1992-10-23(a)

Plaintiffs’ state law claims are based on the same facts supporting plaintiffs’ federal securities claims. They 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. Accordingly, I have jurisdiction over these claims. 28 U.S.C. § 1367(a) (1990).
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Section 1367(a) permits supplemental jurisdiction over disgorgement claims against third parties when they arise from the same scheme as claims within the court’s original jurisdiction.

Securities & Exchange Commission v. Better Life Club of America, Inc. · filed 1998-02-27(a)

Since the claims for disgorgement against the relief defendants arise from the same scheme of securities fraud, they unquestionably meet this standard for supplemental jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state claims that share a common nucleus of operative facts with surviving federal claims.

Meadows v. Pacific Inland Securities Corp. · filed 1999-02-17(a)

Courts may exercise power of supplemental jurisdiction over state claims when the state and federal claims derive from a common nucleus of operative facts. ... In view of the Court’s finding that some of Plaintiffs’ federal claims cannot be dismissed on statutes of limitations grounds, and Plaintiffs have alleged sufficient facts of fraudulent conduct pursuant to Rule 9(b), the Court DENIES the motion to dismiss Plaintiffs’ pendent state law claims.
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Section 1367(a) permits supplemental jurisdiction over state law claims arising from the same transfer of interests as a federal securities claim because they form part of the same case or controversy.

Nelson v. Stahl · filed 2001-11-26(a)

Plaintiffs’ state law claims in the Second through Fifth Causes of Action are, accordingly, so related to their federal claims as to form part of the same case or controversy as required by section 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state-law claims arising from the same factual allegations as remaining federal claims, even if all federal claims against some defendants have been dismissed.

In Re Sterling Foster & Co., Inc., Securities Lit. · filed 2002-06-27(a)

Further, although the Court has dismissed all of the federal causes of action against the Individual Applewoods Defendants, the Court has not dismissed all of the federal causes of action. Because the state-law claims against the IADs, Pace, and Laser-gate arise out of the identical set of factual allegations that form the basis of the plaintiffs’ remaining federal claims, the Court will retain jurisdiction over the remaining state law claims in the interest of judicial economy.
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Section 1367(a) permits supplemental jurisdiction over claims closely interrelated with federal claims.

Valenzuela v. Giumarra Vineyards Corp. · filed 2009-03-31(a)

For the other claims for which AWPA does not provide for a federal cause of action, the court assumes supplemental jurisdiction as the issues appear to be closely interrelated.
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Section 1367(a) permits supplemental jurisdiction over claims that derive from and are closely related to the events giving rise to the underlying action.

Wong v. Yoo · filed 2009-08-18(a)

In this case, supplemental jurisdiction is appropriate, as third-party plaintiffs’ denial of representation claims derive from and are closely related to the events giving rise to the underlying action.
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Section 1367(a) permits supplemental jurisdiction over state-law claims related to a claim within the federal court’s original jurisdiction.

Lans v. Adduci Mastriani & Schaumberg L.L.P. · filed 2011-05-23(a)

Because supplemental jurisdiction extends to all claims related to a claim over which a federal court has original jurisdiction, 28 U.S.C. § 1367(a), and this Court has original jurisdiction over the malpractice claim under § 1338, this Court will also maintain subject-matter jurisdiction over all of the remaining state-law claims in this case.
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Section 1367(a) permits supplemental jurisdiction over substantially overlapping claims when the federal claims are in related actions.

World Trade Center Properties LLC v. Certain Underwriters at Lloyd's, London Syndicates Numbered 1212, 79 & 2791 · filed 2012-11-27(a)

Because substantial overlap exists, the exercise of supplemental jurisdiction over this action is appropriate. That the jurisdiction-providing federal claims are not in this action (but in related actions) does not change this conclusion.
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Section 1367(a) does not confer supplemental jurisdiction over claims unrelated to the claims within the court’s original jurisdiction.

Lath v. City of Manchester, et al. · filed 2018-04-17(a)

Moreover, the claims that Lath asserts against BMS CAT and Amica Mutual Insurance Company (“Amica”), which are the only other claims in this case over which the court has original jurisdiction, see 28 U.S.C. § 1332, are entirely unrelated to the claims that Lath asserts against the City in Causes 2 and 3 and to Lath’s claim against Gerard Dufresne. Accordingly, the court does not have supplemental jurisdiction over those claims. See 28 U.S.C. § 1367(a) (extending supplemental jurisdiction to “claims that are so related to claims in the action within [the court’s] original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution”).
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Section 1367 confers supplemental jurisdiction over state law claims arising from the same set of operative facts as claims within original federal jurisdiction.

Roman Catholic Archdiocese of Kan. City in Kan. v. City of Mission Woods · filed 2018-08-30(a)

Here, plaintiffs' state law claims-the Complaint's Sixth and Seventh Causes of Action-revolve around the same set of operative facts as their federal claims: defendant's decision to deny their application to designate the proposed meeting house as a public use. This means that § 1367 confers jurisdiction over plaintiffs' Kansas law claims.
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Section 1367(a) does not extend supplemental jurisdiction to a fee-sharing contract claim between attorneys that is not factually interdependent with the underlying federal claims.

In re Cmty. Bank of N. Va. Mortg. Lending Practices Litig. specter Specter Evans · filed 2018-12-20(a)

First, SSEM's breach of contract claim is not factually interdependent with the federal claims asserted in CBNV.
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Section 1367(a) permits supplemental jurisdiction over a crossclaim that is closely related to claims within the court’s original jurisdiction.

Union Pacific Railroad v. Utah State Tax Commission · filed 2019-07-17(a)

Therefore, in accordance with the Counties’ arguments that this court has supplemental jurisdiction over the Crossclaim, the court concludes that the Counties’ Crossclaim is so closely related to the 4-R Act claims that supplemental jurisdiction is proper under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over sufficiently related state and city discrimination claims even when some underlying allegations fall outside the federal discrimination claim’s limitations period.

Gao v. Graceful Services, Inc. · filed 2019-10-22(a)

Because the Court denies the motion to dismiss the ADEA claims, the Court also denies the motion to dismiss the NYSHRL and NYCHRL claims, even to the extent those claims are based on allegations of discrimination occurring before August 4, 2017, because the claims are so related as to serve the purposes of 28 U.S.C. § 1367(a).
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Section 1367(a) provides supplemental jurisdiction over a breach of contract claim related to a claim within the court’s original jurisdiction.

Jackson v. Western Architectural Services · filed 2020-05-27(a)

Once a court has original jurisdiction, it also has “supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction.” 28 U.S.C. § 1367(a). Jackson’s breach of contract claim is so related. The court therefore has subject-matter jurisdiction to address the claims Jackson has filed.
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Section 1367 permits supplemental jurisdiction over local claims sharing a common nucleus of operative facts with a federal claim when no statutory ground for declining jurisdiction applies.

Callwood v. Ferdinand Forest, Inc. · filed 2021-11-26(a), (c)

The local claims here satisfy both the “nexus” (common nucleus of operative facts) requirement and the “one proceeding” requirement. Lyon, 45 F.3d at 760. Plaintiff’s claims—both the federal FLSA, and the local claims—revolve around the circumstances surrounding Plaintiff’s employment status with Defendants and the attendant benefits. Further, none of the scenarios under which a district court may decline to exercise supplemental jurisdiction over local claims exist here. Accordingly, the Court has supplemental jurisdiction over the local claims.
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Section 1367(a) permits supplemental jurisdiction over a claim arising from the same facts as a federal question claim.

Williams v. Santander Consumer USA Holding Inc · filed 2022-02-24(a)

The court would therefore have supplemental jurisdiction over this claim under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state-law claims that substantially overlap with a surviving federal claim.

FREITAG v. BUCKS COUNTY · filed 2022-07-12(a)

However, since a § 1983 claim will proceed against PrimeCare, and since the trial of this § 1983 claim will cover very similar if not identical testimony and evidence as a trial of the medical malpractice claims would, the Court will retain supplemental jurisdiction over the medical malpractice claims.
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Section 1367 permits supplemental jurisdiction over related counterclaims; the doctrine governing separate collateral proceedings does not limit that jurisdiction.

BGH Holdings, LLC v. DL Evans Bank · filed 2023-05-03

This body of law is inapplicable to the case at hand, in which there is no “new action” or “collateral proceeding.” Here, subject matter jurisdiction exists as the Court has federal question jurisdiction over plaintiffs’ § 1983 claims and has exercised supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over defendant’s counterclaims. See Dkt. # 149 at 11-14.
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Section 1367(a) permits supplemental jurisdiction over an Unruh Act claim closely related to an ADA claim.

Gonzalez v. The Kind Center, Inc. · filed 2024-06-13(a)

Because Plaintiff’s Unruh Act claim is closely related to his ADA claim, the Court has authority to exercise supplemental jurisdiction over the Unruh Act claim under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over cross-claims closely related to the events underlying a claim within the court’s original jurisdiction.

Shuford v. New York City Department Of Corrections · filed 2025-08-19(a)

Consistent with Judge Cho’s recommendation, supplemental jurisdiction is appropriately exercised because the cross-claims are closely related to the events underlying the Section 1983 claim.
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Section 1367(a) gives a federal court supplemental jurisdiction over a related state-law claim when it has original jurisdiction over a federal claim.

Caballero v. Nissan North America · filed 2026-01-20(a)

To the extent the Court has original jurisdiction over Plaintiff’s Magnuson-Moss Act claim, it also has supplemental jurisdiction over Plaintiff’s related UCC claim.
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Section 1367 covers state claims transactionally related to a federal claim, including claims that arise from identical facts.

Theoda v. Ayre · filed 1996-10-31(a)

As noted, § 1367 provides that where a claim “arising under” federal law is transactionally related to other nonremovable state claims, removal can be based on federal supplemental jurisdiction. Here, the claims against the Municipal and Non-Municipal Defendants are indeed “transactionally related” since they derive from identical facts.
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Section 1367(a) permits supplemental jurisdiction over state claims involving the same parties and alleged nonpayment as federal claims, even when the claims arise from different factual circumstances.

Cole v. Aetna Life & Casualty · filed 1999-08-05(a)

Taking all facts in the complaint as true, as this court must when considering a motion to dismiss, see Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974), the court determines that while the factual scenarios related to the ERISA claims and the Bischoff and Sarnowski claims differ, the claims involve the same plaintiff and the same defendants and involve the same allegation of nonpayment for medical services rendered. A thoughtful consideration of “judicial economy, convenience, and fairness to litigants,” see Seabrook v. Jacobson, 153 F.3d 70, 71 (2d Cir.1998), dictates that this court should not dismiss the state law claims for lack of subject matter jurisdiction and should instead assert supplemental jurisdiction over those causes of action.
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Related antitrust claims

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.

In re Lease Oil Antitrust Litigation · filed 1999-05-10(a)

While the duties under the federal and state causes of action differ, they are “part of the same case or controversy” and share a common nucleus of operative fact. For these reasons, the Court FINDS it is proper to exercise supplemental jurisdiction over the pendent state law claims raised in the consolidated actions.
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Section 1367 permits supplemental jurisdiction over a state antitrust claim that forms part of the same case or controversy as a federal antitrust claim and does not raise a novel or complex issue of state law.

In Re Copper Antitrust Litigation · filed 2000-05-09(a), (c)(1)

The Rhode Island claim forms part of the same case or controversy as the federal claim and does not appear to raise a novel or complex issue of state law. This makes it appropriate for the exercise of supplemental jurisdiction pursuant to 28 U.S.C. § 1367.
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Retaining state claims from federal antitrust allegations

Section 1367(c) allows a court to retain supplemental jurisdiction over state-law claims arising from the same allegations as a federal claim when no novel or complex state-law issues or exceptional circumstances warrant declining jurisdiction.

In Re Urethane Antitrust Litigation · filed 2009-08-14(c)

Plaintiffs' state-law claims are based on the same substantive allegations of a price-fixing conspiracy that support their federal claim, and the Court does not agree with defendants that the case presents novel or complex issues of state law or that exceptional circumstances exist here; accordingly, the Court will not decline to exercise supplemental jurisdiction over the state-law claims in this case pursuant to 28 U.S.C. § 1367(c).
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Section 1367(c) permits a court to retain supplemental jurisdiction over related state-law claims when no novel or complex issue of state law or exceptional circumstance warrants declining it.

Carpenter Co. v. SE · filed 2009-08-14(c)

Plaintiffs' state-law claims are based on the same substantive allegations of a price-fixing conspiracy that support their federal claim, and the Court does not agree with defendants that the case presents novel or complex issues of state law or that exceptional circumstances exist here; accordingly, the Court will not decline to exercise supplemental jurisdiction over the state-law claims in this case pursuant to 28 U.S.C. § 1367(c).
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Related employment claims

Section 1367(a) permits supplemental jurisdiction over state discrimination and retaliation claims arising from the same factual premises as closely related federal claims.

Weatherspoon v. Rock Construction Company, Incorporated · filed 2019-10-16(a)

Second, it is well settled that the exercise of supplemental jurisdiction over ELCRA claims raised on the same factual premises as closely related federal discrimination and retaliation claims is appropriate under 28 U.S.C. § 1367(a).
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Section 1367(a) permits supplemental jurisdiction over state law claims arising from the same alleged acts of sexual harassment as a federal Title VII claim.

Posey v. Calvert County Board of Education · filed 2003-01-14(a)

In the instant case, Plaintiffs state law claims bear a reasonable factual connection to her Title VII claim because the claims arise from the same acts of sexual harassment allegedly perpetrated by Defendant Rizzo. As such, the Court concludes that it may exercise supplemental jurisdiction over Plaintiffs state law claims.
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Section 1367(a) permits supplemental jurisdiction over related state claims joined to a Title VII claim because Title VII does not expressly bar it.

Roy v. Russell County Ambulance Service · filed 1992-12-30(a)

The new supplemental jurisdiction statute suggests, though, that Congress wishes to bar pendent adjudication only in such instances where federal law expressly declares that intent.
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Section 1367(a) permits supplemental jurisdiction over a state human rights claim arising from the same facts as an ADEA claim, where the discrimination evidence substantially overlaps.

Sirota v. Welbilt Appliance, Inc. · filed 1994-01-07(a)

Athough this Court, in Realmuto, supra, declined to exercise pendent jurisdiction over a Human Rights Law claim prior to the Second Circuit’s decision in Promisel, in light of Promisel this Court finds that the exercise of supplemental jurisdiction over plaintiffs HRL Claim is appropriate under 28 U.S.C. § 1367(a). Based on the allegations of the complaint, the ADEA Claim and the HRL Claim arise out of the same facts and the evidence of discrimination will be virtually the same for both claims.
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Section 1367(a) permits supplemental jurisdiction over state discrimination, retaliation, and emotional distress claims that form part of the same case or controversy as claims within the court’s original jurisdiction.

Johnson v. University Surgical Group Associates · filed 1994-11-22(a)

Finally, we believe that we should retain jurisdiction over the Ohio sex discrimination and retaliation claims and the common law emotional distress claims under our supplemental jurisdiction, as these claims “are so related to [the] claims in the action within [our] original jurisdiction that they form part of the same case or controversy----” See 28 U.S.C. § 1367(a); Shrout v. Black Clawson, 689 F.Supp. 774, 781-82 (S.D.Ohio 1988).
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Section 1367(a) permits supplemental jurisdiction over a state assault and battery claim sufficiently connected to a Title VII sexual harassment claim against the employer.

Ammerman v. Sween · filed 1995-05-10(a)

We hold, therefore, that the assault and battery claim was sufficiently connected to the Title VII claim against North Central Technical College to confer jurisdiction on the court to hear the state claim.
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Section 1367 permits supplemental jurisdiction over state employment claims arising from the same termination as federal employment claims because they form part of the same case or controversy.

Dolese v. Office Depot, Inc. · filed 2000-11-21(a)

The district court would have had jurisdiction if the case had been originally filed in district court, as an exercise of supplemental jurisdiction.7 Dolese does not dispute the fact that his TCHRA claims form part of the same case or controversy as his ADA and ADEA claims; all emerge out of the circumstances surrounding his termination.
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Related patent claims

Section 1367(a) permits supplemental jurisdiction over a patent ownership claim related to an infringement claim when proof of ownership is necessary to pursue infringement, despite differences in the claims’ legal issues and evidence.

Loral Fairchild Corp. v. Matsushita Electric Industrial Co. · filed 1994-01-07(a)

While it is true that the issues of ownership and infringement are unrelated in terms of the legal issues and matters of proof, they are yet inextricably intertwined in that proof of one is necessary for action on the other. ... Thus, it would not be improper for this court to exercise its jurisdiction over these defendants; however, this jurisdiction is a doctrine of discretion and although rare, to decline such discretion is not out of the question.
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Section 1367(a) permits supplemental jurisdiction over a foreign patent infringement claim only when it is so related to a claim within original jurisdiction that both form part of the same case or controversy.

Mars Incorporated v. Conlux · filed 1994-04-29(a)

In addition, the district court erred in assuming authority to hear the claim under its supplemental jurisdiction pursuant to 28 U.S.C. § 1367(a) because the claim is not so related to the U.S. patent infringement claim that it forms part of the same case or controversy under Article III of the U.S. Constitution.
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Section 1367(a) permits supplemental jurisdiction over state-law claims arising from the same sales activity as a federal patent claim.

3D Systems, Inc. v. Aarotech Laboratories, Inc., Aaroflex, Inc. And Albert C. Young · filed 1998-11-12(a)

All of the claims arise out of Aaroflex’s sales activity for RP equipment in California, and therefore these claims were properly brought in the district court under the supplemental jurisdiction provision of 28 U.S.C. § 1367.
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Section 1367 permits supplemental jurisdiction over a patent ownership issue that is a necessary predicate to a federal patent non-infringement claim and does not predominate over the action.

Energy Recovery, Inc. v. Hauge · filed 2000-12-01

First, because patent ownership represents, at most, a necessary predicate issue to a determination of patent non-infringement, the Court finds that patent ownership issues do not completely predominate over this action. Second, precisely because patent ownership represents a necessary predicate issue, it is sufficiently related to Plaintiffs patent non-infringement claim to afford Plaintiff a basis for supplemental jurisdiction.
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Section 1367(a) permits a federal court hearing a patent infringement claim to exercise supplemental jurisdiction over a related patent ownership claim that must be resolved before infringement.

Predator International, Inc. v. Gamo Outdoor USA, Inc. · filed 2015-07-14(a)

Although the infringement claim could not be decided before the ownership issue was resolved, the federal court could assume supplemental jurisdiction over the patent-ownership claim, see 28 U.S.C. § 1367(a) (district courts have supplemental jurisdiction “over all other claims that are so related to claims in the action within [the court’s] original jurisdiction that they form part of the same case or controversy”); ... contract).
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Unregistered copyright claims

Section 1367(a) does not confer supplemental jurisdiction over copyright infringement claims involving unregistered works because the Copyright Act’s registration requirement is a federal statutory exception to supplemental jurisdiction.

In Re Literary Works in Electronic Databases Copyright Litigation · filed 2007-11-29(a)

For these reasons, we conclude that § 1367(a) did not provide the District Court with jurisdiction over the claims arising from the alleged infringement of unregistered copyrights.
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Section 1367(a) does not provide supplemental jurisdiction over infringement claims based on unregistered copyrights because 17 U.S.C. § 411(a) bars those claims.

Muchnick v. Thomson Corp. · filed 2007-11-29(a)

For these reasons, we conclude that § 1367(a) did not provide the District Court with jurisdiction over the claims arising from the alleged infringement of unregistered copyrights.
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Related copyright claims

Section 1367(a) permits a federal district court hearing a copyright action to exercise supplemental jurisdiction over a related ownership issue.

EMSA Ltd. Partnership v. Lincoln · filed 1997-04-09(a)

At the very least, the district court would have supplemental jurisdiction under 28 U.S.C. § 1367(a) over the ownership issue in the pending federal action.
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Section 1367 permits supplemental jurisdiction over an accounting claim arising from the same common nucleus of operative fact as federal copyright claims.

Worth v. Universal Pictures, Inc. · filed 1997-10-23(a)

Since this claim is essentially a remedy for Plaintiffs other claims that have been preempted by federal copyright law, this claim can also be removed to federal court based on supplemental jurisdiction. An action for an accounting is derived from a “common nucleus of operative fact” as Plaintiffs other preempted copyright claims.
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Related tort claims

Section 1367(a) permits supplemental jurisdiction over a state tort claim arising from the same alleged conspiracy as a federal antitrust claim because the claims form part of the same case or controversy.

Tacker v. Wilson · filed 1993-08-04(a)

Taking as true the allegations of the Second Amended Complaint, plaintiffs tort claim against Wilson is an outgrowth of the Sherman Act conspiracy and is thus sufficiently related to the antitrust claim as to form part of the same case or controversy as the Sherman Act claim, over which this Court has exclusive jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state law tort claims arising from the same common nucleus of operative fact as a surviving federal claim.

Javid v. Scott · filed 1996-03-04(a)

Because we deny summary judgment dismissing the section 1983 federal claim against Scott, we retain supplemental jurisdiction over plaintiffs’ state law tort claims against Scott as well.
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Section 1367(a) permits supplemental jurisdiction over a territorial tort claim that forms part of the same controversy as a claim within the court’s original jurisdiction.

Eddy v. Virgin Islands Water and Power Authority · filed 1997-02-05(a)

As discussed earlier, a district court may exercise supplemental jurisdiction over claims which form part of the same case or controversy as those claims over which the court has original jurisdiction. Certainly, the intentional infliction of emotional distress claim is part of the same controversy as the deprivation of Mr. Eddy's Fourteenth Amendment rights. Accordingly, the Court will exercise its supplemental jurisdiction over plaintiff's claim for intentional infliction of emotional distress against the individual defendants.
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Related contract claims

Section 1367(a) permits supplemental jurisdiction over a state-law contract claim that arises from the same facts as a federal ERISA claim.

McWilliams v. American Medical International, Inc. · filed 1997-03-18(a)

In the ease at bar, however, AMI’s conflicting interpretation of Mr. McWilliams’ health care coverage as originally being a simple insurance contract and later being an ERISA plan, and its insistence that it honored contracts outside of ERISA it had with other retirees, plus its admission that such extra-ERISA contracts did create liability, bring the state law breach of contract claim within the parameters of this court’s jurisdiction.
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Section 1367 permits supplemental jurisdiction over an employer’s third-party breach-of-contract claim arising from the same unpaid wages as an FLSA claim when no subsection (c) factor applies and judicial economy and fairness favor jurisdiction.

Acosta v. Rab Communications, Inc. · filed 2019-12-27(a), (c)

None of the four factors listed in 28 U.S.C. § 1367(c) applies to this case. ... The breach of contract claim arises out of the same controversy as the FLSA wage claims since the Defendant’s claim is that if the workers were not paid, it is because Fast Pace did not pay them according to the contract between RAB and Fast Pace.
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Contribution and indemnity claims

Section 1367 permits supplemental jurisdiction over related state-law contribution and indemnification claims against a third party when the third-party action was filed after the statute took effect, even if the original action was filed earlier.

Estate of Bruce v. City of Middletown · filed 1992-01-08(a)

To conclude, the court holds that the jurisdictional provisions of § 1367 apply to Middletown’s third-party action and permit the court to exercise pendent party jurisdiction over Middletown’s claims against Movie Center for contribution and indemnification.
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Section 1367 permits supplemental jurisdiction over state-law indemnity claims arising from the same common nucleus of facts as federal civil-rights claims.

Wilson v. City of Chicago · filed 1995-10-03(a)

Moreover, and more importantly, in its January 5, 1995, opinion, this court fully set forth why it has supplemental jurisdiction of plaintiffs and the Officers’ state law claims. The City has presented nothing new to persuade this court that its previous decision was erroneous.
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Section 1367 permits supplemental jurisdiction over a city indemnity claim that is closely related to the underlying claims against its employees.

Spiegel v. City of Chicago · filed 1996-03-22(a)

However, as noted in Ellis v. Bankhead, 828 F.Supp. 45, 47 (N.D.Ill.1993), the supplemental jurisdiction statute, 28 U.S.C. § 1367, has broadened the scope of federal jurisdiction to include those claims that are so related to claims in the action already within the court’s original jurisdiction that they form part of the same case or controversy. The issue of the City’s liability is closely related within the scope of § 1367 to the claims against the individual defendants in this case. Therefore, Spiegel’s claim survives the jurisdictional analysis.
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Section 1367 permits supplemental jurisdiction over a third-party indemnity claim arising from the same transaction or occurrence as a claim within the court’s original jurisdiction.

Robert E. Blake Inc. v. Excel Environmental · filed 1997-01-14(a)

Thus as the third party complaint against Excel alleged that the indemnity claim arose out of the same transaction or occurrence as Pollock’s claims, supplemental jurisdiction was appropriate. 28 U.S.C. § 1367.
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Section 1367(a) permits supplemental jurisdiction over a contribution or indemnity claim arising from medical treatment of an injury at issue in a FELA claim when the claims share a common core of facts concerning the injury and damages.

Lewis v. Cimarron Valley Railroad · filed 2001-09-07(a)

The court further holds that supplemental jurisdiction does exist because the two claims stem from a common core of facts.
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Section 1367(a) permits supplemental jurisdiction over third-party indemnity and contribution claims arising from the subject matter of an action within the court’s original jurisdiction.

Johnson v. D3 Investments, LLC · filed 2025-09-26(a)

In this instance, the indemnity and contribution causes of action raised by Third-Party Plaintiffs against Mr. Sawyer arise out of the subject matter of the original action and involve the same parties and issues. Thus, ancillary jurisdiction exists.
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State claims unrelated to the surviving federal claim

Section 1367(a) does not supply supplemental jurisdiction over state-law claims related only to dismissed federal claims when the surviving federal claim concerns different events.

Eberly v. Harnack · filed 2020-11-12(a)

That is, the claims for intentional infliction of emotional distress (Count 7) and civil conspiracy (Count 8) all arise from what hap- pened after the arrest. The federal law claims to which those claims relate are the Heck-barred federal claims. So there is no supplemental jurisdiction over Counts 7 and 8.
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Section 1367 does not extend supplemental jurisdiction to state-law claims that do not arise from the same case or controversy as the surviving federal claim.

Lurch, Jr. v. The City of NY · filed 2019-12-12(a)

Because these claims do not arise out of the same case or controversy that survives this decision—a police officer’s alleged use of excessive force during an ambulance ride—I decline to exercise supplemental jurisdiction.
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Section 1367(a) does not confer supplemental jurisdiction over a state-law claim that has no factual or legal nexus with the surviving federal claim.

Fisk v. Superannuities, Inc. · filed 1996-06-10(a)

This claim has no factual or legal nexus in common with the lone surviving claim. The requirements of 28 U.S.C. § 1367(a) are not met. Accordingly, the Court lacks subject matter jurisdiction over this claim.
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Section 1367(a) does not give a court supplemental jurisdiction over a state-law claim unrelated to the surviving federal claim.

Thomas v. Chicago Housing Authority · filed 1997-10-09(a)

But, since this action is not related to her First Amendment claim, the only claim that survives this motion, I do not have supplemental jurisdiction to hear it. 28 U.S.C. § 1367(a).
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Section 1367(a) does not reach state claims whose facts differ substantially from those underlying the possible surviving federal claim.

Smylis v. City of New York · filed 1997-11-07(a)

In view of these considerations, the Court holds that neither the negligence claim nor the contention that plaintiff was improperly denied a defense and indemnification with respect to the inmate actions are within the supplemental jurisdiction of this Court.
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Section 1367 permits supplemental jurisdiction over related state law claims, but the court requires a cognizable federal claim before exercising it.

(PC) Cunningham v. Bird · filed 2022-05-02(a)

Although the Court may exercise supplemental jurisdiction over state law claims, Plaintiff must first have a cognizable claim for relief under federal law.
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Section 1367 provides little basis for hearing state claims in an IFP complaint when no federal claim survives screening.

Castaneda v. Frausto-Recio · filed 2024-10-03

But when determining whether to permit the filing of a proposed complaint in an IFP case, § 1367 will provide little basis for filing the complaint when no federal claim survives the screening process. In such circumstances, there is no error in considering whether the state claims are better considered under diversity jurisdiction.
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Section 1367 permits a court to retain supplemental jurisdiction over a state-law claim when a federal claim remains in the suit.

Johnson v. State Board of Embalmers · filed 2025-10-27

Finally, Defendants’ motion to dismiss Count III for lack of supplemental jurisdiction under 28 U.S.C. § 1367 will be denied, as a federal claim remains in this suit.
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Insufficient factual connection

Section 1367(a) does not provide supplemental jurisdiction over state defamation claims arising from events separate from a federal false arrest claim and requiring distinct proof.

Torres v. El Paso Police Department · filed 2020-08-14(a)

The Court finds that the claim for false arrest against Camacho and the claims against the Defamation Defendants do not “form part of the same case or controversy.” 28 U.S.C. § 1367(a).
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Section 1367(a) does not support supplemental jurisdiction over postjudgment claims against additional individuals when those claims lack sufficient factual dependence on the underlying federal claims.

Shaw v. AAA Engineering & Drafting Inc. · filed 2005-06-08(a)

Because Congress intended to codify the doctrine of ancillary jurisdiction as part of “supplemental jurisdiction” in § 1367, id. at 355 n.5, we also believe that Peacock requires us to conclude that the district court would have abused its discretion if it had granted Shaw’s joinder motion and exercised supplemental jurisdiction, as there is simply an “insufficient factual dependence between [plaintiff’s state-law claims and the underlying FCA claims] to justify the extension of [supplemental] jurisdiction.” Id. at 355.
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Section 1367(a) does not permit supplemental jurisdiction over a state law claim whose only factual connection to the federal claim is a shared prison setting and the involvement of prison officials.

Bullock v. Barham · filed 1997-03-12(a)

The only facts in common between the two claims are the prison setting and the involvement of prison officials. These do not constitute a “common nucleus of operative facts.” Accordingly, Mr. Bullock must pursue this claim in state court because I cannot take supplemental jurisdiction over Count II.
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Section 1367(a) does not confer supplemental jurisdiction over a third-party claim that, despite some common facts with the primary claim, would not ordinarily be tried with it as part of the same case or controversy.

Goger v. Merchants Bank of Atlanta (In Re Feifer Industries) · filed 1991-10-10(a)

For the foregoing reasons, the court finds that the Trustee’s claim and Standard Chartered’s third-party claim are not so related that they form part of the same case or controversy which one would ordinarily expect to try in one judicial proceeding. Therefore, the court concludes that Standard Chartered’s third-party action is not within the supplemental jurisdiction of this court.
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Section 1367 does not extend supplemental jurisdiction to state law claims that do not share a common nucleus of operative fact with a federal claim.

Moralez v. Meat Cutters Local 539 · filed 1991-12-13(a)

Thus, removal of an entire case is proper, under this approach, if the state and federal causes of action “derive from a common nucleus of operative fact.” ... In the instant matter, plaintiffs state claims fall far short of the required origin.
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Section 1367(a) requires a supplemental claim to share operative facts with a federal claim; an ongoing dispute between the parties alone does not make the claims part of the same case or controversy.

Council of Unit Owners of the Wisp Condominium, Inc. v. Recreational Industries, Inc. · filed 1992-07-02(a)

Although this claim is part of an ongoing, nasty dispute between the parties, this Court does not think it is part of the same Article III case or controversy such that the claims would ordinarily be tried together.
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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.

Bonilla v. City Council of City of Chicago · filed 1992-12-21(a)

This claim does not derive from a “common nucleus of operative fact” as counts 1 and 3, and is therefore not part of the same case or controversy. Accordingly, the court lacks supplemental jurisdiction over it.
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Section 1367(a) does not confer supplemental jurisdiction over a separate action merely because its claims are related to claims within the court’s jurisdiction in another action.

Lumber Insurance v. Allen · filed 1993-02-12(a)

However, they have failed to cite any authority to support their claim that 28 U.S.C. § 1367(a) permits the court to assert subject matter jurisdiction over claims in one action simply because the court has jurisdiction over related claims in another action. ... Accordingly, I reject the Moores argument that the court has supplemental jurisdiction over the declaratory judgment action in its present form.
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Section 1367(a) does not extend supplemental jurisdiction to a state-law claim merely because it shares a speaker with federal claims; the claims must form part of the same case or controversy.

Obendorfer v. Gitano Group, Inc. · filed 1993-12-02(a)

The Court is of the opinion that Fortney’s defamation claim is not so related to Obendorfer’s sexual harassment and sex discrimination claims as to form part of the “same case and controversy” as the Title VII claims within this Court’s original jurisdiction. Only the maker of the statements is common to the claims.
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Section 1367(a) does not extend supplemental jurisdiction to state law claims concerning particular limited partnerships when the federal RICO claims rest on broader, distinct allegations of fraud.

In Re Colonial Ltd. Partnership Litigation · filed 1994-04-11(a)

First, the state law claims do not derive from "the same case or controversy" as the RICO claims against the co-defendants of American Appraisal and CB. See 28 U.S.C. § 1367(a); United Mine Workers v. Gibbs, 383 U.S. 715, 725, 86 S.Ct. 1130, 1138, 16 L.Ed.2d 218 (1966); see also Ruling on Motions to Dismiss (filed Nov. 18, 1991) at 11-12. The operative facts underlying the RICO claims concern wide-ranging charges of securities fraud, mail fraud, and wire fraud. By contrast, the operative facts underlying the state law claims only concern the particular limited partnerships in which the above defendants were involved.
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Section 1367(a) does not permit supplemental jurisdiction over state employment claims when their only factual link to an FLSA claim is the employer-employee relationship.

Lyon v. Whisman · filed 1995-01-19(a)

In these circumstances it is clear that there is so little overlap between the evidence relevant to the FLSA and state claims, that there is no "common nucleus of operative fact" justifying supplemental jurisdiction over the state law claims.
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Section 1367(a) does not provide supplemental jurisdiction over a state-law claim that is not part of the same Article III case or controversy as the claims within the court’s original jurisdiction.

Ferguson v. Cape Girardeau County · filed 1995-04-12(a)

The Court finds, however, that supplemental jurisdiction does not exist over Count V. A review of the allegations made in support of the claim persuades the Court that the conversion claim does not fall within the statutory scope of such jurisdiction under 28 U.S.C. § 1367(a) because it is not “so related to the claims in the action within [the Court’s] original jurisdiction that [it] form[s] part of the same case or controversy under Article III of the United States Constitution.”
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Section 1367(a) does not confer supplemental jurisdiction over a state-law claim that is only tangentially related to the remaining federal claim.

Chaney v. City of Chicago · filed 1995-08-02(a)

We cannot conclude, however, that the remaining § 1983 claim and the malpractice claim are “so related ... that they form part of the same ease or controversy.” 28 U.S.C. § 1367. While they are tangentially related (ie., one reason that Chaney was in a position to be abused by the prison guards is that Nichols failed to order tests that would prove his innocence), they are, at bottom, two separate and distinct claims.
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Section 1367(a) does not confer supplemental jurisdiction over claims against non-debtors that are not so related to a debtor’s bankruptcy action that they form part of the same case.

In Re Dow Corning Corp. · filed 1995-09-12(a)

Given the facts in the instant case, this Court finds that it does not have supplemental jurisdiction over the claims against the non-debtors. The breast implant actions against the non-debtors are not “so related” to the bankruptcy action that “they form part of the same case.”
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Section 1367(a) does not confer supplemental jurisdiction over a CERCLA defendant’s third-party insurance coverage claim when that claim is insufficiently related to the underlying CERCLA claims.

Johnson Controls, Inc. v. Irving Rubber & Metal Co. · filed 1996-03-21(a)

Returning to the case before us, we find no basis upon which this court could legitimately exercise subject matter jurisdiction over the claims asserted by Ace against Monroe. The claims are not closely enough allied to the underlying CERCLA claims to justify this court’s exercise of supplemental jurisdiction over them.
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Section 1367(a) does not provide supplemental jurisdiction over a state employment termination issue that is factually separate from the federal due process claims and expected to be resolved separately.

Hameli v. Nazario · filed 1996-06-26(a)

These comments, along with the words and actions of the parties, leave little doubt that all concerned regarded the termination hearing as separate from plaintiffs district court suit. Therefore, the court concludes that there was no supplemental jurisdiction over the cause issue.
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Section 1367(a) does not confer supplemental jurisdiction over a counterclaim insufficiently related to the remaining claims to form the same Article III case or controversy.

Amboy National Bank v. Generali — U.S. Branch · filed 1996-06-27(a)

The counter-claim of Somers is insufficiently related to Amboy’s remaining claims to comprise the same case or controversy under Article III. Consequently, under 28 U.S.C. § 1367(a) this Court has no jurisdiction over it and Amboy’s motion to dismiss the counter-claim is granted.
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Section 1367(a) does not permit supplemental jurisdiction over claims arising from separate events involving different defendants and nonoverlapping proof.

Marks v. U.S. Social Sec. Admin. · filed 1996-08-06(a)

Furthermore, we find that it would be inappropriate for the district court to exercise supplemental jurisdiction over these claims should the claims against Drs. Longa and Vinh survive. A district court may exercise supplemental jurisdiction over 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) (1988). Appellants' claims regarding their foreclosure are entirely separate from their claims against the employees of the Department for negligent handling of Ms. Marks's disability claim. None of the Defendants are the same, and the proof required for each claim would not overlap.
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Section 1367(a) does not provide supplemental jurisdiction over a state law claim that has no evidentiary overlap with the federal claims and does not arise from a common nucleus of operative facts.

U.S. ex rel. Hill v. Teledyne, Inc. · filed 1996-11-18(a)

The district court correctly determined there is no evidentiary overlap whatsoever between these claims, properly found they do not derive from a common nucleus of operative facts, and rightly held it lacked supplemental jurisdiction to hear the state law breach of fiduciary duty claim.
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Section 1367(a) does not provide supplemental jurisdiction over a counterclaim that lacks a common nucleus of operative facts with the claim within original jurisdiction.

Keegan v. Bloomingdale's Inc. · filed 1996-11-18(a)

For the reasons discussed above, the Court finds that it lacks supplemental jurisdiction under § 1367(a) over Bloomingdale’s counterclaim.
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Section 1367(a) does not permit supplemental jurisdiction over state law claims that are unrelated to the facts underlying the federal claim.

Stadler v. McCullouch · filed 1996-12-12(a)

There is no basis for this court to exercise supplemental jurisdiction over the state law claims against any of the defendants, since the state law claims are unrelated to the facts underlying the federal ERISA claim.
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Section 1367 does not provide supplemental jurisdiction over state-law claims that do not arise from the same nucleus of operative facts as the federal claims.

Lyle v. Magnolia State Ent · filed 1996-12-17(a)

Moreover, if construed purely as claims pursuant to state law, ... pendent jurisdiction does not attach because these claims do not arise from the same nucleus of operative facts as Lyle’s federal causes of action.
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Section 1367(a) does not confer supplemental jurisdiction over separate class members’ claims arising from discrete transactions merely because they share a defendant’s knowledge of fraud.

Barnett v. Autoplex · filed 1997-08-05(a)

The events leading to each putative class member’s claim are entirely discrete and evidence relating to the financing of each putative class member’s automobile will be different. The sole similar occurrence, and the one around which substantial legal debate will be centered, is a singular knowledge by Chrysler Financial that its financing agreements were fraudulent. However, the issue of knowledge of fraud alone will not make the events giving rise to each putative class member’s claim sufficiently similar to be of the same case or controversy as the claims of the putative class members over which this court has original jurisdiction.
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Section 1367(a) does not provide supplemental jurisdiction over a manufacturer negligence claim whose connection to the federal constitutional claims is too weak to make them part of the same case or controversy.

Hutchinson ex rel. Baker v. Spink · filed 1997-09-23(a)

Even with the remand for further proceedings on the substantive due process claims, the link between these claims and the constitutional claims is too weak to support supplemental jurisdiction. Hutchinson argues that Kill Brothers was negligent in manufacturing the Killsbro Gravity Box and in failing to warn users of its dangers. These allegations are not “so related to claims in the action within such original jurisdiction that they form part of the same case or controversy,” as the supplemental jurisdiction statute requires. 28 U.S.C. § 1367.
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Section 1367(a) does not provide supplemental jurisdiction over a state-law claim arising from a different transaction and set of circumstances than the federal claim.

Clement v. American Honda Finance Corp. · filed 1997-10-30(a)

Even if the parties maintain that Giron is attempting to bring a state law unfair practices claim, the court would not have jurisdiction over this claim because it does not arise, ... as it must, from the same transaction and set of circumstances as the other plaintiffs’ federal CLA claim.
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Section 1367(a) does not allow supplemental jurisdiction over a state-law claim that is insufficiently related to the federal claims to form part of the same case or controversy.

Fromm-Vane v. Lawnwood Medical Center, Inc. · filed 1997-12-12(a)

Upon review of Fromm’s claim under the Florida Whistle-Blower’s Act, Fla. Stat. § 448.101 et seq., the Court determines that the whistle-blower’s claim is not so related to the ADA and Florida Civil Rights Act claims so as to form part of the same case or controversy. 28 U.S.C. § 1367(a). Accordingly, the Court declines to exercise supplemental jurisdiction over Count VI of Fromm’s Complaint.
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Section 1367(a) does not provide supplemental jurisdiction over state claims arising from different transactions without a common nucleus of operative facts with claims under original jurisdiction.

LaFargue v. United States · filed 1998-04-08(a)

It is the Court’s opinion that LIG’s expropriation claim, Count VI, and the remainder of plaintiffs’ claims are not derived from a common nucleus of operative facts as the plaintiffs’ quiet title claims against the Government. Therefore, this Court will not exercise supplemental jurisdiction over Count VI or LIG’s expropriation claim.
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Section 1367(a) does not permit supplemental jurisdiction over state-law claims that do not share a common nucleus of operative fact with claims within the court’s original jurisdiction.

Axel Johnson, Incorporated v. Carroll Carolina Oil Company, Incorporated · filed 1998-06-04(a)

It follows from these arguments and findings that the state-law counts and Superfund counts neither "derive from a common nucleus of operative fact," nor are so closely related that Axel "would ordinarily be expected to try them all in one judicial proceeding," and thus that supplemental jurisdiction could not be exercised over the state-law counts.
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Section 1367 does not confer supplemental jurisdiction over state discrimination claims sharing no common nucleus of operative fact with federal FLSA retaliation claims, and permits declining jurisdiction when the state claims would predominate.

Dervisevic v. Wolfgangs Steakhouse, Inc. · filed 2019-11-22(a), (c)(2)

The Court therefore holds that Plaintiff’s state discrimination claims do not derive from the same common nucleus of operative fact as his FLSA retaliation claim, and, even if they did, the Court would nonetheless decline to exercise supplemental jurisdiction over them because they would predominate over his FLSA retaliation claim.
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Claims requiring additional proof

Section 1367(a) permits supplemental jurisdiction over a state claim arising from the same operative facts as federal claims, even if the state claim requires additional proof.

Hernandez v. City of Hartford · filed 1997-03-14(a)

As to whether plaintiffs state claim is within the court’s subject matter jurisdiction, 28 U.S.C. § 1367 (1994) controls. ... The operative facts underlying plaintiffs claims under the Acts are identical to those under the negligent infliction of emotional distress claim. Although the state law claim may require additional proof, this alone is not enough to preclude the exercise of pendant jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state claims arising from the same case or controversy as federal claims even when the state claims require additional proof.

Brown v. Bronx Cross County Medical Group · filed 1993-10-14(a)

As a threshold matter, the operative facts underlying plaintiffs Title VII claim are identical to those underlying plaintiffs state law claims. Moreover, both the federal and state claims are part of the same case or controversy. While the state law claims may require additional proof beyond that required by the federal claims, this alone is insufficient to prevent the exercise of supplemental jurisdiction. Therefore, the Court has the authority to assert supplemental jurisdiction over plaintiffs state law claims.
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Section 1367(a) permits supplemental jurisdiction over claims by additional plaintiffs that arise from the same case or controversy as a federal claim.

Ziegler v. Ziegler · filed 1998-11-05(a)

The Court has supplemental jurisdiction over the claims of Luke Ziegler and Journee Ziegler because the claims arise out of the same case or controversy as is presented by Michelle Ziegler’s federal cause of action and her state claims. They are proper additional parties.
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Section 1367(a) does not permit supplemental jurisdiction over another plaintiff’s state law claims when they do not arise from the same nucleus of operative fact as the federal claim.

Porter v. Roosa · filed 2003-01-14(a)

Viewed in a different way, because Porter’s claims are not supplemental to Nicolosi’s FLSA claim, had Nicolosi originally filed her cause of action in this Court, Porter would not have been entitled to join the action under § 1367(a), because her own claim claims are not pendent to Nicolosi’s cause of. action.
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Section 1367(a) permits a co-plaintiff to join a claim only when it forms part of the same case or controversy as a claim within the court’s original jurisdiction; an independent claim requires its own basis for jurisdiction.

Hughes v. Region VII Area Agency on Aging · filed 2006-03-28(a)

The Court believes that section 1367(a) provides no statutory authority for Bob Hughes to join this lawsuit as a co-plaintiff with his wife’s section 1983 claim.
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Scope of supplemental jurisdiction

Section 1367 provides no supplemental jurisdiction over the state law claims in this action when federal question jurisdiction is absent.

Allsup v. Liberty Mutual Insurance · filed 1991-12-03(a)

In the absence of federal question jurisdiction, supplemental jurisdiction is likewise not available, see 28 U.S.C. § 1367, and any state law claims that would come before this Court in this case must do so through diversity jurisdiction.
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Section 1367(a) requires supplemental jurisdiction over a pendent party claim that forms part of the same Article III case or controversy as the federal claim.

Ryan v. Cosentino · filed 1991-10-04(a)

If parties seek to invoke pendent party jurisdiction, they need merely demonstrate that the pendent party claim forms part of the “same case or controversy under Article III” as the federal claim. ... Therefore, pursuant to 28 U.S.C. § 1367(a), the Court’s exercise of supplemental jurisdiction is mandatory.
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Section 1367 permits supplemental jurisdiction over state-law claims when the alleged causes of injury form part of the same controversy and the claims would be expected to be tried together.

Urban v. King · filed 1992-01-07

The court concludes, because of the nature of the alleged injuries, that plaintiffs would be expected to try all of their claims together. When several causes combine to cause a harm, as they are alleged to have done here, the causes are part of the same controversy, and the court finds that supplemental jurisdiction is properly exercised. The court will retain jurisdiction over the claims asserted against defendant Shuk-man and the other physicians.
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Section 1367(a) preserves the preexisting scope of pendent jurisdiction under Gibbs.

Freiburger v. Emery Air Charter, Inc. · filed 1992-06-01(a)

Although the language may differ between the statute and prior case law, this court believes that § 1367(a) neither expanded nor contracted the scope of pendent jurisdiction.
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Section 1367(a) permits supplemental jurisdiction over state law claims arising from the same alleged discriminatory acts as a Title VII claim.

Godfrey v. Perkin-Elmer Corp. · filed 1992-05-26(a)

Furthermore, plaintiff’s federal and state claims are all based upon the same alleged discriminatory acts and, given the duplication and waste of judicial resources that separate trials would entail, plaintiff would be expected to try them all in a single proceeding. ... Accordingly, the court finds that it has the power to exercise supplemental jurisdiction over plaintiff’s state law claims, subject only to the narrow circumstances detailed by Congress.
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Section 1367(a) permits supplemental jurisdiction over an intervening plaintiff’s state-law claims in an EEOC Title VII action.

Equal Employment Opportunity Commission v. Century I, L.C. · filed 1992-06-25(a)

Mr. Woods’ state law claims, however, are not futile as a matter of law. This court has supplemental jurisdiction over those claims pursuant to 28 U.S.C. § 1367(a). Defendants’ argument that this court has no jurisdiction over those claims is without merit.
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Section 1367(a) does not allow supplemental jurisdiction over otherwise disconnected claims merely because they share an important legal issue.

Turner Broadcasting System, Inc. v. Federal Communications Commission · filed 1993-01-05(a)

First, while the overlap of an important legal issue is in some circumstances grounds for intervention, see, e.g., Nuesse v. Camp, 385 F.2d 694, 701-02 (D.C.Cir.1967), plaintiffs cite no authority for the idea that such an overlap is enough for supplemental jurisdiction over otherwise disconnected claims. Again, the proposition would radically expand the idea of a "common nucleus of operative fact".
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Section 1367(a) permits supplemental jurisdiction over a state claim seeking different relief when it shares a central fact pattern with a claim under federal jurisdiction.

White v. County of Newberry · filed 1993-02-05(a)

The claims need only revolve around a central fact pattern. Here the Whites have presented two claims that revolve around alleged hazardous waste contamination caused by the County. Regardless of the outcome of the case, the two claims' proof will rest on the central issue of whether the County released TCE into the area groundwater. We find this commonality sufficient to support supplemental jurisdiction under section 1367 as a matter of law.
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Section 1367 permits a district court to retain state-law claims based on the same facts as federal claims when they raise no novel or complex state-law issues and do not predominate over the federal claims.

Shane v. State of Conn. · filed 1993-03-24(a), (c)

Applying the test set forth in section 1367, it is clear that the exercise of pendent jurisdiction over plaintiffs state law claims is appropriate. The state law claims in this ease are based on the identical facts as the federal claims and allege unlawful termination. They do not raise novel or complex issues of state law. Moreover, consideration of these claims neither expands the scope of issues nor predominates over federal claims. Accordingly, this court declines to dismiss plaintiffs state law claims pursuant to section 1367.
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Notes 2101–2250 of 23,839, oldest cases first.

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