Finley v. United States
490 U.S. 545 (1989)
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Rule of Law:
A grant of jurisdiction to a federal court over claims involving particular parties does not in itself confer jurisdiction over additional claims by or against different parties for which no independent basis of federal jurisdiction exists.
Facts:
- On November 11, 1983, a twin-engine plane carrying Norita Finley's husband and two children crashed during its approach to a San Diego airfield.
- The crash occurred when the plane struck electric transmission lines, and there were no survivors.
- Finley initially believed the crash was caused by the negligence of San Diego Gas and Electric Company for its positioning of the transmission lines.
- Finley also believed the City of San Diego was negligent for its maintenance of the airport's runway lights, which were inoperative.
- Finley later discovered that the Federal Aviation Administration (FAA), a federal agency, was the party responsible for the runway lights, not the city.
- All claims against the United States, the utility company, and the city arose from the single event of the plane crash.
Procedural Posture:
- Norita Finley filed a tort action against San Diego Gas and Electric Company and the City of San Diego in California state court.
- Finley subsequently filed a separate action against the United States in the U.S. District Court for the Southern District of California, asserting jurisdiction under the Federal Tort Claims Act (FTCA).
- In the federal action, Finley moved to amend her complaint to add claims against San Diego Gas and Electric and the City of San Diego.
- The District Court granted the motion, asserting pendent-party jurisdiction over the non-federal defendants.
- The District Court certified the jurisdictional question for an interlocutory appeal.
- The U.S. Court of Appeals for the Ninth Circuit summarily reversed the District Court, holding that pendent-party jurisdiction is not available under the FTCA.
- The U.S. Supreme Court granted certiorari to resolve a split among the circuit courts.
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Issue:
Does the Federal Tort Claims Act (FTCA), which grants federal district courts exclusive jurisdiction over civil actions on claims against the United States, permit a court to assert pendent-party jurisdiction over additional defendants for whom no independent basis of federal jurisdiction exists?
Opinions:
Majority - Justice Scalia
No. The Federal Tort Claims Act does not permit the assertion of pendent-party jurisdiction over defendants for whom there is no independent basis for federal jurisdiction. Federal courts are courts of limited jurisdiction, and any grant of jurisdiction must be explicitly conferred by Congress. The doctrine of pendent-claim jurisdiction established in Mine Workers v. Gibbs, which allows federal courts to hear state-law claims between parties already properly before the court, does not extend to bringing in new parties (pendent-party jurisdiction). Citing Aldinger v. Howard and Owen Equipment & Erection Co. v. Kroger, the Court held that adding new parties requires a more rigorous analysis of the specific jurisdictional statute. The text of the FTCA, which confers jurisdiction over “civil actions on claims against the United States,” is interpreted narrowly to mean claims against the United States and no one else. The Court rejected the argument that a 1948 revision to the statute's language was intended to substantively broaden jurisdiction, viewing it instead as a stylistic change to conform with the Federal Rules of Civil Procedure. Ultimately, a grant of jurisdiction over a particular party is not a grant of jurisdiction over other parties, and Congress must provide a clear statement to authorize such an expansion.
Dissenting - Justice Blackmun
Yes. The proper question under Aldinger is not whether Congress affirmatively granted pendent-party jurisdiction, but whether it demonstrated an intent to exclude such parties. The FTCA contains no such expression of congressional intent to exclude private defendants. Where, as here, the grant of federal jurisdiction is exclusive, making the federal forum the only one where the entire constitutional 'case' can be heard together, the sensible result is to permit the exercise of pendent-party jurisdiction for reasons of judicial economy and convenience.
Dissenting - Justice Stevens
Yes. The Court's holding departs from precedent and the modern understanding of a constitutional 'case' as defined in Gibbs, which encompasses all claims arising from a 'common nucleus of operative fact.' The proper rule from Aldinger is that pendent jurisdiction is permissible unless Congress has expressly or by implication negated its existence. The FTCA contains no such negation. The fact that the FTCA grants exclusive jurisdiction to federal courts is a powerful reason to allow pendent-party jurisdiction, as it is the only way to try all related claims in a single proceeding. The majority incorrectly relies on diversity cases like Zahn and Kroger, which involved specific, congressionally mandated jurisdictional limits not present here. By requiring an affirmative grant instead of looking for a negation, the Court adopts a new, unnecessarily grudging interpretive rule.
Analysis:
This decision established a clear, strict rule requiring an express statutory basis for pendent-party jurisdiction, effectively eliminating the doctrine as it had been developing in the lower courts. It created significant practical problems for plaintiffs whose claims involved both the U.S. government and private parties, forcing them into inefficient and costly separate lawsuits in federal and state courts. The ruling's restrictive interpretation of federal jurisdiction was highly controversial and prompted a direct legislative response. In 1990, Congress enacted 28 U.S.C. § 1367, the supplemental jurisdiction statute, which explicitly overruled the Finley holding and authorized pendent-party jurisdiction in most federal question cases, codifying a framework closer to the dissent's view.
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