Carlsbad Tech., Inc. v. HIF Bio, Inc. (2008)
- Docket
- 07-1437
- Decided
- 2008-01-01
Summary
Question: Is a federal district court order to remand a case to state court properly understood as stripped of any federal claims when the district court declines supplemental jurisdiction and is thus barred from federal appellate review? Conclusion: No. The Supreme Court held that a district court's decision not to exercise supplemental jurisdiction over a state-law claim is not a dismissal for lack of federal subject matter jurisdiction for which federal appellate review is barred. With Justice Clarence Thomas writing for a unanimous Court, it reasoned that, in this case, the district court merely exercised its discretion to dismiss a state-law claim for which it had supplemental jurisdiction, and therefore its decision was not based upon lack of jurisdiction, which would have precluded federal appellate court review. Justice John Paul Stevens, Justice Antonin G. Scalia, and Justice Stephen G. Breyer joined by Justice David H. Souter, all wrote separate concurring opinions. Each highlighted the mess the Supreme Court's holdings have left this area of law and suggested statutory revision to clarify the law.