After All Federal Claims Dismissed, District Court May Exercise Supplemental Jurisdiction over State Law Claims, As to Which There Is No Independent Federal Jurisdiction, Where to Do So Would Promote Judicial Economy
Hinterberger v. Kaleida Health, 2013 U.S. App. LEXIS 17469 (2d Cir. Aug. 21, 2013):
The employees argue that once the district court dismissed their RICO claim, it should have declined to exercise supplemental jurisdiction over their remaining claims. We disagree. The Supreme Court has made it abundantly clear--in a case that also involved a dismissed RICO claim — that "[a] district court's decision whether to exercise [supplemental jurisdiction over state-law claims] after dismissing every claim over which it had original jurisdiction is purely discretionary." Carlsbad Tech., 556 U.S. at 639 (citing 28 U.S.C. § 1367(c)). The district court's decision to exercise supplemental jurisdiction here was a wise exercise of judicial economy, not an abuse of discretion.
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