Lewis V Richardson

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Automated Summary

Key Facts

On July 2, 1992, Karen Lewis was driving a vehicle containing her three minor children in Hopkinton, New Hampshire when it collided with a vehicle driven by defendant Myra C. Richardson. Richardson had been charged with and pled guilty to failure to stop at a stop sign and traffic light in violation of state statutes. The plaintiffs, Karen Lewis and her three minor children, brought a negligence action for injuries sustained in the automobile accident. Ralph Lewis, Jr., Karen's husband, brought a claim for loss of consortium. The court denied the defendant's motion to dismiss for lack of subject matter jurisdiction, finding that supplemental jurisdiction under 28 U.S.C. § 1367(a) applied because all claims derived from the common nucleus of operative facts—the automobile collision.

Issues

  • The defendant argued that each pendent plaintiff failed to assert claims establishing an amount in controversy in excess of $50,000, exclusive of interest and costs, in accordance with 28 U.S.C. § 1332(a). The court determined that given the exercise of supplemental jurisdiction under § 1367(a), it need not determine whether each pendent plaintiff presented claims in excess of $50,000 to establish original jurisdiction.
  • The defendant moved to dismiss the claims of pendent plaintiffs Ralph Lewis, Jr., Michelle Lewis, Michael Lewis, and Ralph Lewis, III for lack of subject matter jurisdiction. The defendant conceded jurisdiction over Karen Lewis' claim but argued the pendent plaintiffs failed to establish an amount in controversy exceeding $50,000. The court analyzed whether 28 U.S.C. § 1367(a) grants supplemental jurisdiction over claims that form part of the same case or controversy under Article III, and whether the pendent plaintiffs' claims arise from the common nucleus of operative fact of Karen Lewis' negligence claim. The court held that all claims derive from the same automobile accident and negligence incident, thus invoking supplemental jurisdiction.

Holdings

The court denies the defendant's motion to dismiss the claims of Michelle Lewis, Ralph Lewis, III, Michael Lewis, and Ralph Lewis, Jr. for lack of subject matter jurisdiction. The court finds that the case falls squarely within its supplemental jurisdiction under 28 U.S.C. § 1367(a) because each pendent plaintiff's claim arises from the common nucleus of operative fact of Karen Lewis' claim, which is over which the court has original diversity jurisdiction.

Legal Principles

  • The court may exercise supplemental jurisdiction over pendent claims that are so related to claims over which the court has original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution. Section 1367(a) of 28 U.S.C. authorizes federal court jurisdiction over supplemental claims even where the supplemental claims do not independently meet the amount in controversy requirement set forth in § 1332. The court finds that each of the pendent plaintiffs' claims arises from the 'common nucleus of operative fact' of Karen Lewis' claim such as to invoke the court's supplemental jurisdiction under § 1367(a).
  • Under 28 U.S.C. § 1367(a), district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution. This includes claims that involve the joinder or intervention of additional parties. The court may not exercise jurisdiction in a manner inconsistent with Article III, § 2 of the United States Constitution.
  • The plaintiffs argue that the court has original diversity jurisdiction over the claims asserted by each pendent plaintiff, or alternatively that the court should exercise supplemental jurisdiction under 28 U.S.C. § 1367 because the claims derive from a common nucleus of operative facts. The parties do not dispute that they are citizens of different states in accordance with 28 U.S.C. § 1332(a)(1).

Precedent Name

  • Garza v. Nat'l Am.Ins. Co.
  • Garita Hotel Ltd. Partnership v. Ponce Federal Bank
  • Palumbo v. Roberti
  • United Mine Workers of Am. v. Gibbs
  • Owen Equip. & Erection Co. v. Kroger
  • Acton Co., Inc. of Mass. v. Bachman Foods, Inc.

Cited Statute

  • New Hampshire Revised Statutes Ann. Section 265:9 and 31
  • United States Code Title 28 Section 1332(a)
  • United States Code Title 28 Section 1367

Judge Name

Joseph A. DiClerico, Jr.

Passage Text

  • Section 1367(a) unambiguously authorizes federal court jurisdiction over supplemental claims 'so related' to claims over which the court has original jurisdiction, even where the supplemental claims do not independently meet the amount in controversy requirement set forth in § 1332.
  • The court finds that each of the pendent plaintiffs' claims arises from the 'common nucleus of operative fact' of Karen Lewis' claim such as to invoke the court's supplemental jurisdiction under § 1367(a).
  • The defendants' motion to dismiss the claims of Michelle Lewis, Ralph Lewis, III, Michael Lewis, and Ralph Lewis, Jr. for lack of subject matter jurisdiction (document no. 9) is denied.