United Mine Workers v. Gibbs 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed. 2d. 218 (1966) Gibbs was hired as a mine superintendent by Grundy Corp., a wholly-owned subsidiary of Tennessee Consolidated Coal Co. o As part of the arrangement, Grundy also gave Gibbs an independent contract to haul coal. The United Mine Workers (UMW) were in conflict with the Southern Labor Union. They forcibly prevented the opening of the mine Gibbs was to be in charge of. Several people were beaten. Gibbs lost his job as a mine superintendent. He also lost the opportunity to haul coal. He lost other contracts and suspected that the UMW was plotting against him. He sued the International UMW (as opposed to the local branch) for violations of the Labor Management Relations Act (LMRA). He also asserted State law claims for conspiracy. o Since the LMRA was a Federal Statute, Gibbs brought the claim in Federal Court. o Although the conspiracy charge was a State law claim, Gibbs was able to add it to the Federal Court claim under the doctrine of pendent jurisdiction (aka Rule 18(a)). The doctrine of pendent jurisdiction says that Federal Courts have discretion to hear pendent State claims where there is a substantial Federal claim arising out of a common nucleus of operative fact. Since there was no diversity jurisdiction or anything like that, Gibbs would not have been able to sue UMW in Federal Court if he was only alleging the State claim. In order to qualify for pendant jurisdiction the case has to come out of the same set of operative facts. The jury in the Trial Court found for Gibbs and awarded $174k in damages. o The jury found that the UMW had violated the LMRA Project Wonderful - Your ad here, right now, for as low as $0 and State conspiracy laws. The Trial Court judge sustained a motion saying that the pressure the UMW put on Grundy to fire Gibbs was a dispute between Grundy and UMW, and Gibbs had no standing to sue under the LMRA. o However, there was Tennessee State law that would have granted Gibbs recovery. Therefore the Trial judge sustained the claim as a State law claim. UMW appealed on the basis that since the Federal claim was thrown out, the Federal Court had no jurisdiction to decide a case that was solely a State claim. The Appellate Court affirmed. UMW appealed. The US Supreme Court reversed (but only on the merits). o The US Supreme Court found that State law claims are appropriate for Federal Court determination if they form a separate but parallel ground for relief also sought in a substantial claim based on Federal law. Since Gibbs claims are such that he would ordinarily be expected to try them all in one judicial proceeding, then assuming the substantiality of the Federal issues, the Federal Court can decide the entire case hear the whole. o The US Supreme Court found that once it appears that a State claim constitutes the real body of a case, and the Federal claim is only an appendage, the State claim may fairly be dismissed without prejudice and left for a State Court. o It is within the discretion of the Federal Court to have dismissed the State claim, but there is no error in its refusal to do so. It's the Federal Court's choice. o The US Supreme Court then reversed the decision and threw out the State claim on the merits of the case. They agreed that the Federal Courts all had jurisdiction, they just didn't think Gibbs proved his case. Basically, this case is saying that as long as you have a legitimate Federal Claim, you can sue in a Federal Court and bring a State claim along with you. If the Federal claim gets dismissed, the Federal Court can dismiss the State claim and allow you to go to a State Court, or they can continue to hear the State claim. It's the Federal Court judge's choice. o Pendent jurisdiction (aka supplemental jurisdiction) can allow a Federal Court to hear a claim even though there is no diversity jurisdiction or Federal question jurisdiction. See 28 U.S.C. § 1367(a).
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