United Mine Workers v. Gibbs
Yeazell, pp. 244-248
Facts: Gibbs was a manager who got in trouble with a union and was shut out of work. He sued the union for sort of conspiring to keep him out of the mining business. He had two theories and thus two claims: one state claim and one federal claim. The state claim was basically a tort claim, I think. The federal claim was based on a federal labor statute.
Procedural Posture: The federal district court said the federal statute didn’t really apply to the situation, but that the state claim was good to go. The United Mine Workers appealed eventually to the Supreme Court, apparently both on the merits and on the question of whether the district court had jurisdiction to hear the state claim.
Issue: Was it proper for the district court to exercise jurisdiction over the claim based on state law?
Rule: NEW(ish) RULE! Whenever a federal claim that federal courts could properly hear under the “federal question” branch of subject matter jurisdiction is brought along with a state claim that comes out of the same facts as the federal claim, a federal court may (not must) exercise pendant jurisdiction.
Analysis: The Court gives some guidelines for using pendant jurisdiction.
· When a clump of claims is a candidate for pendant jurisdiction, it is up to the discretion of the lower federal courts whether or not to hear the state part of the clump.
· The main reason the federal courts should be allowed to do this is in the interest of efficiency and (to a lesser degree) fairness. If exercising pendant jurisdiction would be unfair or inefficient, the federal courts should decline to do so.
· The court shouldn’t overreach and make decisions about state law, because (1) the federal government should play nice with the states, and (2) state courts may be better equipped to deal with questions of state law.
The Court also lists some factors that a federal court ought to consider in deciding whether to exercise pendant jurisdiction:
1. If the federal claims are dismissed before trial, then the federal court can feel safe in dismissing the state claim, too.
2. If the state issues predominate, the state claims can be dismissed without prejudice to be dealt with in state court.
3. If the state claim is very closely tied to federal issues, you might keep the state claim in. Brennan suggests that this is true in the present case.
4. If the jury sitting in the federal court is likely to be confused by working with two different sets of laws, that justifies separating out the federal and state claims.
The Court says that you can bring up subject matter jurisdiction and dismiss state claims at any time, even though it is customary and desirable to get these issues out of the way when you get the pleadings. But don’t forget that a Rule 12(b)(1) motion (lack of subject matter jurisdiction) is the most favored defense and can be brought up by anyone at any time!
In the present case, the Court says that the district court acted properly in hearing the state case because there was a federal “pre-emption” issue.
Conclusion: The district court properly exercised jurisdiction over the state claim, although it could have chosen not to. However, the plaintiff loses on the merits.
Notes and Problems
1. Refer to 28 U.S.C. § 1367, which more or less codifies the rule of Gibbs.
a. I guess what the Court is saying is that Article III gives federal courts the power to hear the case, and the case includes both the federal and state claims. Article III says: “The judicial Power shall extend to all Cases [emphasis added], in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority”.
b. § 1367(a) codifies the finding of this Court that the Constitution authorizes federal jurisdiction over cases as well as controversies. This Court construes the word “cases” pretty broadly, and the statute codifies just such an interpretation.
c. We want to join claims together! It’s faster, better and cheaper to knock off 15 lawsuits in one fell swoop rather than having to try them all separately when they all relate to the same thing. Also, if you don’t try the federal and state claims together, you’ll have some really confusing preclusion issues.
a. Gibbs says that you shouldn’t exercise supplemental jurisdiction when: (1) there is an important or difficult issue of state law involved, (2) it would be confusing to the jury to use two different sets of laws at once, (3) the federal claim gets dismissed before trial and just the state claim is left, or (4) a state court could better handle issues of state law.
b. The statute doesn’t mention what I listed as #4 above.