Supplemental Jurisdiction

Snapshot 1: A second plaintiff attempts, before the enactment of 28 U.S.C. § 1367, to add a non-federal claim against a defendant already defending a lawsuit with a claim that has an independent basis for federal jurisdiction.

Snapshot 2: A second plaintiff attempts, after the enactment of 28 U.S.C. § 1367, to add a non-federal claim against a defendant already defending a lawsuit with a claim that has an independent basis for federal jurisdiction.

Snapshot 3: A defendant attempts to bring a non-federal claim against a plaintiff that has sued the defendant on claim with an independent basis for federal jurisdiction.

Unless otherwise noted, the potential additional claims are assumed to be factually related to the underlying claim such that they form part of the same "case or controversy".

For all of the post-1367 results, bear in mind that the court may, in proper circumstances, choose to decline to exercise its supplemental jurisdiction. See § 1367(c). Similarly, under pre-1367 laws, courts had some discretion to decline jurisdiction over pendent claims and, to a lesser degree, ancillary claims. See United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (pendent jurisdiction); Joiner v. Diamond M. Drilling Co., 677 F.2d 1035 Cir. 1982) (ancillary jurisdiction); Coleman v. Casey Bd. of Educ., 686 F.2d 428 Cir. 1982) (ancillary jurisdiction).