Jinks v. Richland Cty. - 538 U.S. 456, 123 S. Ct. 1667 (2003)

Rule:

28 U.S.C.S. § 1367(d) is necessary and proper for carrying into execution Congress's power to constitute tribunals inferior to the United States Supreme Court, U.S. Const. art. I, § 8, cl. 9, and to assure that those tribunals may fairly and efficiently exercise the judicial power of the United States, U.S. Const. art. III, § 1. As to "necessity," the federal courts can assuredly exist and function in the absence of 28 U.S.C.S. § 1367(d), but the Supreme Court rejects the view that the Necessary and Proper Clause demands that an Act of Congress be "'absolutely necessary'" to the exercise of an enumerated power. Rather, it suffices that § 1367(d) is conducive to the due administration of justice in federal court, and is plainly adapted to that end. Section 1367(d) is conducive to the administration of justice because it provides an alternative to the unsatisfactory options that federal judges faced when they decided whether to retain jurisdiction over supplemental state-law claims that might be time barred in state court.

Facts:

Petitioner filed a federal-court action claiming that respondent county and others violated 42 U.S.C. § 1983 in connection with her husband's death. She also asserted supplemental claims for wrongful death and survival under South Carolina law. The District Court granted defendants summary judgment on the § 1983 claim and declined to exercise jurisdiction over the state-law claims. Petitioner then filed the supplemental claims in state court and won a wrongful-death verdict against respondent. The State Supreme Court reversed, finding the state-law claims time-barred. Although they would not have been barred under § 1367(d)'s tolling rule, the court held § 1367(d) unconstitutional as applied to claims brought in state court against a State's political subdivisions. Petitioner appealed. 

Issue:

Was the tolling provision of 28 U.S.C.S. § 1367(d) unconstitutional as applied to lawsuits brought against political subdivisions? 

Answer:

No.

Conclusion:

The United States Supreme Court held that § 1367(d) was a valid exercise of the congressional power to enact necessary and proper laws conducive to the due administration of justice in federal courts, and political subdivisions were not excepted from the operation of the statute. Section 1367(d) permitted federal courts to determine whether to exercise supplemental jurisdiction over state law claims without undue consideration of state limitations period and eliminated the serious impediment to access to the federal courts for plaintiffs asserting both federal and state claims. Further, the state's authority to set substantive, rather than procedural, conditions upon which its political subdivisions were subject to suit in its own courts was not immune from federal congressional regulation. Accordingly, the judgment dismissing petitioner's lawsuit as time-barred was reversed and the case was remanded for further proceedings.