Federal Jurisdictional Update


By: Owen T. Rooney
Title 28 of the United States Code Section 1367(d) allows for federal supplemental jurisdiction over state law claims. This statute, as now construed by the US Supreme Court in Artis v. District of Columbia, holds that the statutes of limitations on any state law claims stops while the claim is in federal court, such that the act of filing in federal court acts as a “stop clock” on any limitation period applied to a state law claim. This means that, in the event the district court enters judgment on federal claims and then dismisses state law claims, i.e., declines to retain jurisdiction over them, plaintiffs will have all of the remaining time on their state claims when the federal action was filed  plus 30 days.
Notably, this decision overrules the district court and the DC Circuit Court of Appeals decisions against Artis, as well as the California Supreme Court’s 2014 decision in City of Los Angeles v. County of Kern.
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