Finley v. United States Case Brief

Why is the case important?

Petitioner, Finley, sought to combine the defendants in a civil action and bring the suit into federal court because that is the only place the federal government could be sued.

Facts of the case

Question

The issue is whether Petitioner can establish pendent jurisdiction in federal courts over defendants with state claims when there is no independent basis for bringing the action there.

Answer

The majority of the United States Supreme Court held that just because the Act required Respondent to be challenged in federal court does not mean that other defendants can be brought into federal court if there is no independent basis for doing so. There needs to be more than a common nucleus of facts, but rather express authority given by Congress or through the Constitution.

Conclusion

The court affirmed the judgment holding that the district court could not assert jurisdiction over parties who were not otherwise subject to federal jurisdiction in petitioner widow’s action against respondent government under the Federal Tort Claims Act (FTCA). Pendent jurisdiction was not available because the FTCA conferred federal jurisdiction only over civil actions on claims against the United States. Since it expressed no intention to include jurisdiction over other parties, pendent-party jurisdiction was not available over claims against the government.

  • Case Brief: 1989
  • Petitioner: Finley
  • Respondent: United States
  • Decided by: Rehnquist Court

Citation: 490 US 545 (1989)
Argued: Feb 28, 1989
Decided: May 22, 1989