Law School Case Brief
Van Harken v. City of Chi. - 103 F.3d 1346 (7th Cir. 1997)
When a federal claim drops out before trial, the federal district court should relinquish jurisdiction over the supplemental claim. If, however, an interpretation of state law that knocks out the plaintiff's state claim is obviously correct, the federal judge should put the plaintiff out of his misery then and there, rather than burdening the state courts with a frivolous case.
In 1990 the City of Chicago adopted a new system for the adjudication of parking violations.The new system made a violation a civil rather than criminal offense and did not require the ticketing officer to be at the hearing for challenge. Parking violators filed a class action, challenging this system on behalf of persons who, either having been adjudged liable for a parking violation in contested proceedings under the new procedures and paid their fines or having received a parking ticket and still having time to contest it. The action claimed that the new procedures violated the due process clauses of the United States and Illinois constitutions. The district judge dismissed the suit for failure to state a claim under either constitution.
Was dismissal proper?
The court affirmed the dismissal of the parking violators' claim against the city. It held that the test for due process in the sense of procedural minima required a cost-benefit comparison. The court concluded that appellee's procedures for dealing with parking violations satisfied the requirements of federal due process. The court, however, modified the district court's judgment, finding that because the federal claim had dropped out before trial the district court should have relinquished jurisdiction over the supplemental state claim, because the due process clauses of the Illinois constitution and the federal constitution were not coterminous, therefore the presumption was in favor of dismissing the state claim without an examination of the merits.
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