Brief Fact Summary. A group of 51 visiting Chinese Nationals, U.S. residents and U.S. citizens filed a defamation suit against the People’s Republic of China, in Federal District Court.
Synopsis of Rule of Law. To determine when assertion of supplemental jurisdiction is appropriate, District Court must determine whether state and Federal claims derive from common nucleus of operative fact and, if so, whether judicial economy, convenience and fairness to litigants weigh in favor of doing so
When deciding state-law claims under diversity or supplemental jurisdiction, federal courts apply the choice-of-law rules of the jurisdiction in which they sit.View Full Point of Law
Issue. When is supplemental jurisdiction appropriate?
Held. The Supreme Court of the United States held that although the exercise of supplemental jurisdiction was warranted, the claim was dismissed because it was time barred by the statute of limitations. When a Federal court has an independent basis for exercising Federal jurisdiction, it may in certain circumstances, also exercise supplemental jurisdiction over related claims under state law. To determine when assertion of supplemental jurisdiction is appropriate, district court must determine whether state and Federal claims derive from common nucleus of operative fact and, if so, whether judicial economy, convenience and fairness to litigants weigh in favor of doing so Ultimately the Supreme Court held that the exercise of supplemental jurisdiction over the Falun Gong members’ state law defamation claims against the Chinese television corporation was warranted even though the practitioners were domiciled in different states, because the defamation claims formed a key part of the alleged overarching campaign to abridge and nullify the practitioners’ rights and liberties.
Discussion. In reading the Supreme Court’s opinion students should keep in mind that, unlike an general assertion of subject matter jurisdiction, in considering whether it has jurisdiction over the case, the Court may consider materials outside the pleadings. Students should also keep in mind that when deciding state-law claims under supplemental jurisdiction, Court applies choice-of-law principles of forum jurisdiction. Ultimately, the Supreme Court decided the matter on practical grounds, finding that the defamation claim did not raise complex issues of state law that outweighed the court’s interest in promoting judicial economy