"[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action... that they form part of the same case or controversy," 28 U.S.C. § 1367, i.e., "derive from a common nucleus of operative fact," City of Chicago v. Int'l Coll. of Surgeons, 522 U.S. 156, 165, 118 S.Ct. 523, 139 L.Ed.2d 525 (1997) (internal quotation marks omitted). "In general, where the federal claims are dismissed before trial, the state claims should be dismissed as well." Marcus v. AT&T Corp., 138 F.3d 46, 57 (2d Cir.1998). That said, a district court does not abuse its discretion where the "values of judicial economy, convenience, fairness, and comity" support the exercise. Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343, 350, 108 S.Ct. 614, 98 L.Ed.2d 720 (1988). Delaney v. Bank of America Corp., 766 F. 3d 163 (2nd Cir. 2014).
Federal courts are tribunals of limited subject matter jurisdiction. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377, 114 S.Ct. 1673, 128 L.Ed.2d 391 (1994). They may only hear cases that invoke an independent basis of federal subject matter jurisdiction. Federal courts are also permitted to entertain claims or incidental proceedings that do not satisfy the requirements of an independent basis of subject matter jurisdiction. "Supplemental" or "pendant" jurisdiction applies to claims asserted in a pending federal-court case. "Ancillary" jurisdiction applies to related proceedings that are technically separate from the initial case that invoked federal subject-matter jurisdiction. See generally 13 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 3523, at 154 (3d ed.2008) ("Wright & Miller"). Whereas "supplemental" or "pendant" jurisdiction is treated under 28 U.S.C. § 1367, "ancillary" jurisdiction is governed by case law. Kokkonen provides the guiding framework:
Generally speaking, we have asserted ancillary jurisdiction (in the very broad sense in which that term is sometimes used) for two separate, though sometimes related, purposes: (1) to permit disposition by a single court of claims that are, in varying respects and degrees, factually interdependent, ... and (2) to enable a court to function successfully, that is, to manage its proceedings, vindicate its authority, and effectuate its decrees....
511 U.S. at 379-80, 114 S.Ct. 1673 (internal citations omitted); see also Local Loan Co. v. Hunt, 292 U.S. 234, 239, 54 S.Ct. 695, 78 L.Ed. 1230 (1934) ("That a federal court of equity has jurisdiction of a bill ancillary to an original case or proceeding in the same court, whether at law or in equity, to secure or preserve the fruits and advantages of a judgment or decree rendered therein, is well settled."). US v. Field, 756 F. 3d 911 (6th Cir. 2014).
THIS CASEBOOK contains a selection of 33 U. S. Court of Appeals decisions that analyze and interpret the doctrine of supplemental jurisdiction. The selection of decisions spans from January 2012 to the date of publication.