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Whitney v. Marut

April 3, 2008

GLEN J. WHITNEY AND CHRISTINA M. WHITNEY, PLAINTIFFS,
v.
JOSEPH MARUT, ROBERT S. STOUD, AND JOHN HAGERTY, DEFENDANTS



The opinion of the court was delivered by: Judge Conner

MEMORANDUM

The present memorandum is a sua sponte evaluation of the court's subject matter jurisdiction over several claims in the above-captioned matter. The underlying case is a federal civil rights action brought by plaintiff Glen Whitney ("Glen") against defendant police officers Joseph Marut and Robert Stoud (collectively "Marut and Stoud") arising from his criminal prosecution. Plaintiff Christina Whitney ("Christina") asserts state law claims against defendant John Haggerty*fn1 ("Haggerty"), who, in turn, alleges state law counterclaims against Glen. The court, in its memorandum and order dated February 25, 2008 (Doc. 23), directed Christina and Haggerty to file briefs addressing whether their state law claims properly invoke the court's supplemental jurisdiction pursuant to 28 U.S.C. § 1367.*fn2 The instant memorandum follows the parties' briefing of this issue.

I. Factual Background*fn3

In January 2005, Glen and Christina attended a party at which Haggerty was also a guest. (Doc. 1 ¶ 11-12.) After a few hours, Glen returned home, leaving Christina to socialize with the other guests. (Id. ¶ 12.) Christina and Haggerty eventually left the party together and went to Haggerty's residence, where they engaged in sexual intercourse. (Doc. 1 ¶ 11-12; Doc. 9 ¶ 23, 36.) Christina alleges that this activity was forced and nonconsensual, (Doc. 1 ¶ 12); Haggerty claims that it was voluntary and that Christina had suggestively flirted with him on several previous occasions,*fn4 (Doc. 9 ¶¶ 36-37).

Clifford Grosvenor ("Grosvenor"),*fn5 a guest at the party and a friend of Glen, noticed Christina and Haggerty leave together and telephoned Glen to inform him of the situation. (Id. ¶ 13.) Glen and Grosvenor traveled to Haggerty's residence, and upon arrival Grosvenor forcibly entered through the front door, after which he exchanged punches with Haggerty. (Doc. 1 ¶ 14; Doc. 9 ¶¶ 14, 38.) Haggerty alleges that Glen participated in the altercation, though Glen acknowledges no role in the scuffle. (Doc. 9 ¶ 38.) The evening ended when Christina, Glen, and Grosvenor left Haggerty alone at this residence. (Doc. 9 ¶ 40.) In the days that followed, Marut and Stoud, both of whom are police officers, criminally prosecuted Glen and Grosvenor for the alleged unauthorized entry and assault that occurred at Haggerty's residence. (Doc. 1 ¶¶ 17-21.) Glen was found not guilty of all charges. (Id. ¶ 22.)

Glen and Christina instituted the present action on January 16, 2007. Glen alleges federal claims for malicious prosecution and unlawful seizure against Marut and Stoud arising from their prosecution of him. (Doc. 1 ¶¶ 7, 25.) He predicates these claims upon the court's federal question jurisdiction. Christina alleges no claims against Marut and Stoud but advances state law tort claims for assault and battery against Haggerty associated with the allegedly involuntary sexual intercourse. (Id. ¶ 29.) Haggerty has counterclaimed against Glen for tortious assault and battery for the alleged fisticuffs that took place at Haggerty's home. (Doc. 9 ¶¶ 33-46.) Both Christina and Haggerty's claims rest upon the court's supplemental jurisdiction. On February 25, 2008, the court directed Christina and Haggerty to address whether their state law claims properly invoke this jurisdiction. The parties have briefed this issue, which is now ripe for disposition.

II. Discussion

Haggerty concedes his counterclaim should be dismissed if the court declines to exercise jurisdiction over Christina's state law claims.*fn6 (Doc. 25 at 8.) The court will therefore evaluate whether Christina's claims properly rely on the court's supplemental jurisdiction.

Supplemental jurisdiction has been a historically a difficult field. See, e.g., 13 CHARLES ALAN WRIGHT ET AL., FEDERAL PRACTICE AND PROCEDURE §§ 3523-3523.1, 3567-3567.3 (3d ed. 2002). The adjudicative authority of district courts is statutorily and constitutionally limited, with few exceptions, to cases arising under federal law or involving diverse defendants. Id. § 3522; see also 28 U.S.C. §§ 1331, 1332. That this jurisdiction may also extend to "supplemental" claims, factually linked to a federal cause of action but lacking an independent jurisdictional basis, is a relatively recent development. See id. § 1367; see also Sinclair v. Soniform, Inc., 935 F.2d 599, 603 (3d Cir. 1991); 13 WRIGHT ET AL., supra, §§ 3523-3523.1, 3567-3567.3.

Nevertheless, it is now well settled that district courts may entertain such claims so long as they share a "common nucleus of operative facts" with claims over which the court could exercise original jurisdiction. Lyon v. Whisman, 45 F.3d 758, 759-60 (3d Cir. 1995) (quoting United Mine Workers v. Gibbs, 383 U.S. 715, 725 (1966)).

This authority is not an obligation, however. Congress has conferred on district courts the discretion to decline to exercise supplemental jurisdiction when state law claims "substantially predominate" over the federal causes of action. 28 U.S.C. § 1367(c)(2). Federal courts evaluate the predominance of state claims by reference to three factors: (1) the evidentiary proof required to advance them, (2) the comprehensiveness of the remedy sought, and (3) the scope of issues that they raise. Mazurkiewicz v. Doylestown Hosp., 223 F. Supp. 2d 661, 667 (E.D. Pa. 2002); see also Gibbs, 383 U.S. at 726-27; see also Borough of West Mifflin v. Lancaster, 45 F.3d 780, 787-90 (3d Cir. 1995) (interpreting Gibbs as an outline of the analytical framework applicable to a court's discretionary exercise of supplemental jurisdiction). This tripartite analysis, first discussed by the Supreme Court in Gibbs, permits simultaneous resolution of intertwined federal and state claims while avoiding "[n]eedless decisions of state law."*fn7 Gibbs, 383 U.S. at 726-27.

Turning to the threefold Gibbs analysis, to the first factor addresses whether the state claims substantially predominate over the federal claims in terms of the evidentiary matters they present. See Lancaster, 45 F.3d at 789. A federal court may decline to hear state claims that require a "substantial quantity" of evidence unrelated to the federal claims. Id. However, refusal to exercise supplemental jurisdiction is appropriate "only where 'a state claims constitutes the real body of a case, to which the federal claim is only an appendage.'" Id. (quoting Gibbs, 383 U.S. at 727). State and federal claims that exhibit evidentiary parity should be heard in a single litigation. Id.; see also Lackman v. Recovery Servs., No. Civ. 06-2016, at *3 (D.N.J. Nov. 29, 2006).

In the present case, Glen's federal claims focus upon a single inquiry, viz., whether Marut and Stoud had probable cause to prosecute Glen for his alleged conduct at Haggerty's residence. This inquiry, in turn, focuses entirely on the actions that Glen took at Haggerty's home on the evening at issue. Christina's claims, by contrast, implicate myriad evidentiary matters. Evidence regarding Christina and Haggerty's long-term relationship, their activity upon arrival at his residence, past sexual conduct, the amount of alcohol both individuals had consumed, and their ability to engage rational decision-making may all affect the success of her claims. None of this evidence has any bearing on Glen's federal claims. A comparison between the weighty issues of proof associated Christina's state law claims and the relatively narrow issues of proof implicated by their federal counterparts suggests that Christina's claims substantially predominate the present case. Accordingly, the first factor of Gibbs counsels against exercising supplemental jurisdiction over Christina's claims.

The second Gibbs factor evaluates "the scope of the issues raised" by the state claims. See Gibbs, 383 U.S. at 726. A court may refuse to entertain state claims that raise a substantial number of issues that have no bearing on federal recovery, though it should not decline jurisdiction merely because state claims outnumber federal ones. Lancaster, 45 F.3d at 789-90 (holding that a federal court may not decline to hear state claims merely ...


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