Finely v. United States, 490 U.S. 545, was a case that the Supreme Court of the United States heard and decided in 1989.[1] The case addressed the jurisdictional requirements of the Federal Tort Claims Act. In response to the Finely decision, the United States Congress enacted 28 U.S.C. § 1367[1].[2]
| Finley v. United States | |
|---|---|
 | |
| Argued February 28, 1989 Decided May 22, 1989 | |
| Full case name | Barbara Finley v. United States |
| Citations | 490 U.S. 545 (more) 109 S. Ct. 2003 |
| Argument | Oral argument |
| Court membership | |
| |
| Case opinions | |
| Majority | Scalia, joined by Rehnquist, White, O'Connor, Kennedy |
| Dissent | Blackmun |
| Dissent | Stevens, joined by Brennan, Marshall |
| Laws applied | |
| Federal Tort Claims Act | |
Superseded by | |
| 28 U.S.C. § 1367 | |
Background edit
In 1983, Barbara Finley's husband and two of their children were flying into San Diego, California. As the plane approached San Diego, it flew into electric transmissions, causing the plane to crash. None of the passengers survived.[3]
Finley sued in state court, alleging that San Diego Gas and Electric Company had been negligent in illuminating the transmission lines, and that the city of San Diego had been negligent in maintaining the runway lights. Finley subsequently learned that the Federal Aviation Administration was responsible or the runway lights, so she brought a new lawsuit in the United States District Court for the Southern District of California.[1] Finley's complaint asserted that the federal district court had jurisdiction under the Federal Tort Claims Act. Later, Finely amended her federal complaint to re-assert her claims against the state-court defendants. There was no independent basis for jurisdiction over those parties.[3]
The District Court granted Finley's motion based on a pendent jurisdiction theory like that of United Mine Workers of America v. Gibbs. The Supreme Court granted certiorari to determine whether the FTCA permits pendent-party jurisdiction.[1]
Decision edit
Justice Scalia, quoting Chief Justice Marshall, stated that "two things are necessary to create jurisdiction, whether original or appellate. The Constitution must have given to the court the capacity to take it, and an act of Congress must have supplied it."[3] The majority distinguished United Mine Workers, asserting that it viewed Congress' delegation of jurisdiction more narrowly.[1]
Justices Stevens and Blackmun both dissented, arguing that pendent-party jurisdiction allows federal courts to fashion more complete relief in a more efficient manner.[3]
Aftermath edit
Congress passed 28 U.S.C. 1367 in response to Finley.[2]
References edit
- ^ a b c d "Finley v. United States, 490 U.S. 545 (1989)". Justia Law. Retrieved 2023-10-06.
- ^ a b Subrin, Stephen; Minow, Martha; Brodin, Mark; Main, Thomas; Lahav, Alexandra (2020). Civil Procedure: Doctrine, Practice, and Context (6th ed.). Aspen. pp. 914–917. ISBN 9781543820911.
- ^ a b c d "Barbara FINLEY, Petitioner v. UNITED STATES". LII / Legal Information Institute. Retrieved 2023-10-06.