490 U.S. at 555-556
On the night of November 11, 1983, a twin-engine plane carrying petitioner's husband and two of her children struck electric transmission lines during its approach to a San Diego, California, airfield.1 No one survived the resulting crash.2 Petitioner first filed a tort action in state court against San Diego Gas and Electric Company and the city of San Diego.3 She alleged that the utility had negligently positioned and inadequately illuminated the transmission lines. She also alleged that the city had negligently maintained the airport's runway lights.4
After learning that the Federal Aviation Administration was responsible for the runway lights, petitioner filed the present action against the United States in the United States District Court for the Southern District of California.5 The federal complaint invoked jurisdiction under the Federal Tort Claims Act, 28 U.S.C. § 1346(b).6 It alleged negligence by the FAA in the operation and maintenance of the runway lights and in air traffic control functions.7
Almost a year later, petitioner moved to amend the complaint to add her state-law claims against the utility and the city.8 No independent basis for federal jurisdiction existed for those claims.9 The District Court granted the motion.10 It asserted pendent jurisdiction under Mine Workers v. Gibbs. The court certified an interlocutory appeal under 28 U.S.C. § 1292(b).11
The Court of Appeals for the Ninth Circuit summarily reversed.12 It relied on its earlier decision in Ayala v. United States, which had rejected pendent-party jurisdiction under the FTCA. The Supreme Court granted certiorari to resolve a split among the circuits on whether the FTCA permits assertion of pendent jurisdiction over additional parties.13
Whether the Federal Tort Claims Act authorizes a federal district court that has original jurisdiction over a claim against the United States to exercise pendent-party jurisdiction over related state-law tort claims against additional nonfederal defendants?14
The Federal Tort Claims Act, 28 U.S.C. § 1346(b), grants district courts exclusive jurisdiction over civil actions on claims against the United States for money damages arising from the negligent or wrongful acts of federal employees acting within the scope of their employment.15 Pendent-party jurisdiction over additional nonfederal defendants on state-law claims is unavailable unless the governing jurisdictional statute affirmatively authorizes it.16 This principle was established in Aldinger v. Howard and Owen Equipment & Erection Co. v. Kroger.17 The FTCA's text limits jurisdiction to claims against the United States and contains no such authorization.18
No. The FTCA's jurisdictional grant in 28 U.S.C. § 1346(b) is expressly limited to civil actions on claims against the United States.19 Petitioner sought to append state-law claims against the city of San Diego and San Diego Gas and Electric Company to her FTCA action.20 These claims lacked an independent jurisdictional basis such as diversity of citizenship.21 Although the District Court found that the claims derived from a common nucleus of operative fact, it favored judicial economy.22 The Court of Appeals and the Supreme Court held that the statute does not extend to additional parties.23 The text specifies jurisdiction over claims against the United States and no one else.24 The 1948 revision did not effect a substantive change to allow pendent-party jurisdiction.25
This conclusion follows from the principle that federal courts are tribunals of limited jurisdiction defined by Congress.26
The Federal Tort Claims Act does not authorize a federal district court to exercise pendent-party jurisdiction over related state-law tort claims against additional nonfederal defendants.27
Related opinions on this issue
Joined by Justice Brennan, Justice Marshall, And Justice Stevens
Justice Blackmun dissented.28 He argued that the majority's decision continues a campaign to trim the scope of federal jurisdiction. The decision is not compelled by statute or precedent. It is inconsistent with the principles of judicial economy and fairness that underlie the doctrine of pendent jurisdiction. He read the Court's opinion in Aldinger as requiring consideration of whether Congress has demonstrated an intent to exempt the party as to whom pendent jurisdiction is asserted from being haled into federal court.29 This approach differs from demanding an affirmative grant of pendent-party jurisdiction. In his view, the FTCA contains no such substantive limitation.30 There is also no expression of congressional intent to exclude private defendants from federal tort claims litigation.
Blackmun noted that United States v. Sherwood is distinguishable.31 There is no equivalent history of adjudication of tort claims against the United States in a tribunal without power to litigate the liability of private tortfeasors. He emphasized that where the grant of jurisdiction to a federal court is exclusive, as in FTCA cases, the sensible result is to permit the exercise of pendent-party jurisdiction.32 This allows the entire constitutional case to be heard as a whole in the only possible forum. He would have reversed the judgment of the Court of Appeals.
Joined by Justice Brennan And Justice Marshall
Justice Stevens filed a lengthy dissent.33 He contended that the Court's holding is not faithful to precedents. It casually dismisses the accumulated wisdom of the best judges. He explained that Article III permits federal courts to decide cases to which the United States is a party.34 The FTCA unquestionably authorizes jurisdiction over civil actions on claims against the United States. Stevens argued that joinder of private defendants does not defeat this power.35 Federal Rules of Civil Procedure 14(a) and 20(a) authorize impleader and joinder of joint tortfeasors. The entire three-cornered controversy derives from a common nucleus of operative fact.
He traced the history of pendent and ancillary jurisdiction through Gibbs.36 Numerous courts of appeals had recognized pendent-party jurisdiction after that decision. Stevens criticized the majority for treating the absence of an affirmative grant as an implicit rejection.37 This approach is contrary to Aldinger's rule that pendent jurisdiction exists unless Congress has expressly or by implication negated it. He distinguished diversity cases from federal-question cases like the FTCA.38 Exclusive jurisdiction makes the federal forum the only one in which all claims can be tried together.39 He urged following the enlightened view of waiver of sovereign immunity from United States v. Yellow Cab rather than strict construction from Sherwood.40 Stevens would hold that the grant of jurisdiction authorizes hearing state-law claims against pendent parties.41