City of Chicago v. International College of Surgeons
522 U.S. 156 (1997)
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Rule of Law:
A federal district court has subject matter jurisdiction over a case removed from state court that contains both federal constitutional claims and state law claims seeking on-the-record judicial review of a local administrative agency's decisions. The court's original jurisdiction arises from the federal questions, and it may exercise supplemental jurisdiction over the related state law claims.
Facts:
- The International College of Surgeons (ICS) owned two properties on North Lake Shore Drive in Chicago, which included historic mansions.
- In July 1988, the Chicago Landmarks Commission made a preliminary determination that the buildings on ICS's properties qualified for designation as part of a landmark district.
- In February 1989, ICS entered into a contract to sell its properties to a developer, which planned to demolish parts of the mansions to construct a high-rise tower.
- In June 1989, the Chicago City Council officially designated the area, including ICS's properties, as a landmark district, restricting demolition.
- In October 1990, ICS applied to the Commission for permits to allow for the partial demolition required by the development contract.
- The Commission denied the permit applications, finding the proposed demolition would destroy significant historical features.
- ICS then reapplied for the permits under an economic hardship exception provided in the ordinance.
- The Commission again denied the applications, finding that ICS did not qualify for the hardship exception.
Procedural Posture:
- Following the Commission's permit denials, ICS filed two lawsuits for judicial review in the Circuit Court of Cook County, an Illinois state trial court.
- The complaints raised federal constitutional claims as well as state law claims seeking administrative review.
- The City of Chicago removed both actions to the U.S. District Court for the Northern District of Illinois based on federal question jurisdiction.
- The District Court consolidated the cases, exercised supplemental jurisdiction over the state claims, and granted summary judgment in favor of the City.
- ICS, as appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit.
- The Seventh Circuit reversed, holding that the District Court lacked jurisdiction because the on-the-record state law claims were appellate in nature and not within a district court's 'original jurisdiction.'
- The City of Chicago, as petitioner, successfully sought a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does a federal district court have subject matter jurisdiction over a civil action removed from state court that contains both federal constitutional claims and state law claims seeking on-the-record judicial review of a local administrative agency's decision?
Opinions:
Majority - Justice O’Connor
Yes, a federal district court has subject matter jurisdiction over such a civil action. The propriety of removal to federal court depends on whether the case could have originally been filed there. ICS's complaint included several federal constitutional challenges, which are claims 'arising under' federal law, thereby establishing the district court's original 'federal question' jurisdiction under 28 U.S.C. § 1331. Once original jurisdiction over the federal claims was established, the district court could properly exercise supplemental jurisdiction over the related state law claims under 28 U.S.C. § 1367(a), because both the federal and state claims derived from a 'common nucleus of operative fact'—the Commission's denial of demolition permits. The fact that the state law claims required deferential, on-the-record review does not strip the federal court of this jurisdiction, as the nature of the state claim is relevant to supplemental, not original, jurisdiction.
Dissenting - Justice Ginsburg
No, a federal district court does not have subject matter jurisdiction over such an action. The Court's decision improperly authorizes 'cross-system appeals,' allowing federal district courts to act as appellate tribunals for local administrative agency rulings, a role they are not meant to play. The on-the-record review of an agency decision is 'classically appellate in character' and does not constitute a 'civil action' within a district court's 'original jurisdiction.' By blurring the critical distinction between a de novo proceeding and a deferential appellate-style review, the majority permits an unwarranted federal intrusion into the state's role of developing and applying its own administrative law, a function that state courts are better suited to perform. Congress did not intend for the supplemental jurisdiction statute to create such a significant reallocation of power from state to federal courts.
Analysis:
This decision significantly clarifies and arguably expands the scope of federal supplemental jurisdiction under 28 U.S.C. § 1367. It establishes that the presence of state law claims requiring deferential, on-the-record review of administrative decisions does not defeat federal jurisdiction if the case also contains legitimate federal questions. This ruling provides a pathway for challenges to local administrative actions, such as zoning or permitting decisions, to be heard in federal court so long as a colorable federal claim is included. While the Court affirms federal jurisdiction, it also highlights that district courts retain discretion under § 1367(c) and abstention doctrines to decline hearing the state claims, preserving some judicial flexibility and respect for comity.
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