Hurn v. Oursler
289 U.S. 238, 53 S. Ct. 586, 1933 U.S. LEXIS 176 (1933)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
When a federal court has jurisdiction over a substantial federal claim, it may also adjudicate a related state-law claim if the state claim is not a separate cause of action but rather a different ground for relief arising from the same set of operative facts.
Facts:
- Petitioners Hurn and others composed and obtained a federal copyright for their play, 'The Evil Hour.'
- Petitioners later created a revised, but uncopyrighted, version of the play.
- The central feature of 'The Evil Hour' was the representation of a spiritualistic seance on stage in which the audience was invited to participate.
- Petitioners submitted their play to Respondents Oursler and others for consideration for production.
- Respondents owned a play called 'The Spider,' which, as originally written, did not contain a seance scene.
- After reviewing Petitioners' play, Respondents altered 'The Spider' to incorporate a spiritualistic seance and other elements allegedly taken from 'The Evil Hour.'
- All parties involved in the dispute were citizens of the same state, precluding diversity jurisdiction.
Procedural Posture:
- Petitioners filed suit in federal district court against Respondents, alleging federal copyright infringement and state-law unfair competition.
- The trial court found on the merits that Respondents' play did not infringe Petitioners' copyright.
- The trial court then concluded that, with the federal claim resolved, it lacked jurisdiction to hear the state-law unfair competition claims and dismissed the entire bill on that basis.
- The U.S. Circuit Court of Appeals affirmed the district court's dismissal for lack of jurisdiction.
- The Supreme Court of the United States granted certiorari to review the jurisdictional question.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal court have jurisdiction to decide a state-law claim of unfair competition when it is joined with a federal copyright infringement claim, if both claims arise from the same set of facts, even if the copyright claim is ultimately dismissed on the merits?
Opinions:
Majority - Mr. Justice Sutherland
Yes. A federal court has jurisdiction over a non-federal claim that is joined with a substantial federal claim when they are not separate causes of action but rather different grounds supporting the same underlying cause of action. The Court distinguished between two scenarios: 1) a case with a single cause of action supported by two distinct grounds (one federal, one state), and 2) a case with two separate and distinct causes of action (one federal, one state). In the first scenario, if the federal ground is substantial, the court may retain jurisdiction over the entire case and decide the state-law ground even if the federal ground is ultimately rejected on the merits. Here, the claims of copyright infringement and unfair competition regarding the copyrighted play both arose from the same facts—the alleged misappropriation of Petitioners' work. They constituted a single cause of action, so the district court had jurisdiction to decide both. In contrast, the unfair competition claim regarding the uncopyrighted version of the play was a separate and distinct cause of action based purely on state law, with no federal question involved. Therefore, the district court was correct to dismiss that specific claim for lack of jurisdiction.
Analysis:
This landmark decision established the doctrine of 'pendent jurisdiction,' which allows federal courts to hear state-law claims that derive from a 'common nucleus of operative fact' as a substantial federal claim. The ruling promotes judicial economy by preventing parties from having to litigate the same factual dispute in two different court systems (federal and state). This doctrine was later codified and expanded into the modern concept of 'supplemental jurisdiction' under 28 U.S.C. § 1367. The case's distinction between a single 'cause of action' with multiple legal theories and 'separate and distinct causes of action' became a critical, though often challenging, analytical framework for federal courts assessing the scope of their jurisdiction.
