Brief Fact Summary. Petitioner, Finley, sought to combine the defendants in a civil action and bring the suit into federal court because that is the only place the federal government could be sued.
Synopsis of Rule of Law. Parties that otherwise could not be sued in federal courts can not be brought into federal court solely on the basis of having their claims share the same facts as the claim mandated to the federal courts.
Issue. The issue is whether Petitioner can establish pendent jurisdiction in federal courts over defendants with state claims when there is no independent basis for bringing the action there.
Held. The majority of the United States Supreme Court held that just because the Act required Respondent to be challenged in federal court does not mean that other defendants can be brought into federal court if there is no independent basis for doing so. There needs to be more than a common nucleus of facts, but rather express authority given by Congress or through the Constitution.
When the grant of jurisdiction to a federal court is exclusive, for example, as in the prosecution of tort claims against the United States under 28 U. S. C. § 1346, the argument of judicial economy and convenience can be coupled with the additional argument that only in a federal court may all of the claims be tried together.View Full Point of Law
United States Supreme Court Justice John Paul Stevens argued that 16 years of precedent coupled with a lack of Congressional disapproval demonstrated that state claims brought in such a manner is not only acceptable but sensible. Under this ruling, plaintiffs will have to bring two separate cases.
Discussion. The majority read the Act very literally and hence narrowly. Congress eventually overruled the decision by passing a supplemental jurisdiction statute that allowed for the combination of claims in federal court.