Case Citator › United Mine Workers of America v. Gibbs

United Mine Workers of America v. Gibbs

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Supreme Court of the United States
Citation
383 U.S. 715
Decided
Confirmed treatments
2
Flagged citations read
213 of 213
Citing cases (total)
13,839
Treatment dates
1991–1993
Superseded by statute
A reviewed court treats this case as superseded by later legislation. All 213 flagged citations for United Mine Workers of America v. Gibbs have been read, confirming two adverse treatments listed below. Scott v. School District No. 6 held that 28 U.S.C. § 1367 superseded Gibbs's nonstatutory pendent-jurisdiction regime, and Cedillo v. Valcar Enterprises & Darling Delaware Co. held that the statute cabins Gibbs's broad discretion.
More on how this was screened

The other opinions applied Gibbs, reported statutory or case history, rejected adverse arguments, or contained unrelated treatment language.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

13,839 later cases cite United Mine Workers of America v. Gibbs; 213 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United Mine Workers of America v. Gibbs?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by Statute

  • The court held that 28 U.S.C. § 1367 superseded Gibbs's pendent-jurisdiction doctrine and supplied the governing statutory basis for supplemental jurisdiction.

    Scott v. School District No. 6 · D. Wyo. · filed

    The statute supersedes United Mine Workers of America v. Gibbs, 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed.2d 218 (1966) and overrules Finley v. United States, 490 U.S. 545, 109 S.Ct. 2003, 104 L.Ed.2d 593 (1989).
    Read the full opinion on CourtListener →

Limited

  • The court held that § 1367 cabins Gibbs's discretionary framework by requiring supplemental jurisdiction unless a statutory exception applies.

    Cedillo v. Valcar Enterprises & Darling Delaware Co. · N.D. Tex. · filed

    The decision whether to exercise pendent jurisdiction has always been a matter within the court’s discretion. See Gibbs, 383 U.S. at 726, 86 S.Ct. at 1139 (“It has consistently been recognized that pendent jurisdiction is a doctrine of discretion, not of plaintiff’s right”). Because § 1367(a) codifies pendent jurisdiction, the discretionary element of the doctrine is necessarily retained. But the statute also cabins that discretion by mandating that supplemental jurisdiction be exercised unless one of the categories in § 1367(c) is met.
    Read the full opinion on CourtListener →

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