UNITED MINE WORKERS OF AMERICA v. GIBBS
(Mine Workers Union) v. (Mine Supervisor)

Facts: Gibbs (P) sued the United Mine Workers (D) on both state and federal claims and the Supreme Court now reviews the district court’s decision to hear both claims to determine whether federal jurisdiction was appropriate.

Issue:  Does a federal court have jurisdiction over a plaintiff’s state law claims as well as his federal law claims?

Rule: A federal court may hear a plaintiff’s state law claims, based on the doctrine of pendent jurisdiction, whenever one claim arises under federal law and the state and federal claims derive from a common nucleus of operative fact.

Analysis: Pendant jurisdiction exists whenever the state and federal claims are so closely related as to comprise on constitutional case.  A federal court should not exercise pendant jurisdiction if the state issues predominate.  It is also unwarranted if there is a substantial likelihood of a jury confusing the legal theories of the federal and state claims.

Conclusion: The federal district court did not abuse its discretion by taking jurisdiction over Gibb’s state law claims, since his federal claim clearly arose under federal law and since the scope of Gibbs state claim implicated the federal doctrine of pre-emption.