## Facts

- Monica Aldinger was employed in the Spokane County Treasurer’s office and was discharged without a hearing by the county treasurer.
- Aldinger filed suit in federal district court against the county treasurer, other county officers, and Spokane County.
- She asserted federal constitutional claims under 42 U.S.C. § 1983 and invoked jurisdiction under 28 U.S.C. § 1343(3).
- She also asserted a related state-law claim against Spokane County, arguing the court could hear it under pendent jurisdiction because it arose from the same operative facts.
- Under then-prevailing interpretation of § 1983, counties were not “persons” subject to suit under § 1983.

## Issues

1. Whether a federal court with § 1343(3) jurisdiction over § 1983 claims against individual county officials may exercise pendent jurisdiction to adjudicate a state-law claim against a county that is not otherwise within federal jurisdiction.
2. Whether Article III “case or controversy” power alone permits adding a new party (a county) for a state-law claim, or whether statutory jurisdiction must specifically authorize such pendent party jurisdiction.

## Decision

- The Supreme Court affirmed the Ninth Circuit’s judgment upholding dismissal of Spokane County.
- The Court held the district court lacked statutory jurisdiction to hear the pendent state-law claim against the county.
- The Court distinguished pendent claim jurisdiction between existing parties from the attempt to use a state-law claim to bring in a new party over whom no independent federal jurisdiction existed.

## Legal Principles

- Article III may permit federal adjudication of related nonfederal claims within the same case or controversy, but federal courts may exercise such authority only to the extent Congress has conferred jurisdiction by statute.
- Pendent party jurisdiction is not automatically available merely because the state-law claim shares a common nucleus of operative fact with the federal claim.
- In evaluating pendent party jurisdiction, courts must construe the particular jurisdictional statute and the substantive federal statute; where Congress has excluded a class of defendants from the federal cause of action, courts should not expand federal jurisdiction indirectly to reach those defendants via pendent state claims.
- Under § 1343(3) in combination with § 1983 as then interpreted, Congress did not authorize federal jurisdiction that would allow joining a county solely to litigate a state-law claim.

## Conclusion

Because § 1343(3) and § 1983 did not provide a statutory basis to hale a county into federal court, the district court could not use pendent jurisdiction to add Spokane County as a new party for a state-law claim, even if the state and federal claims arose from the same operative facts.


Aldinger v. Howard, 427 U.S. 1 (1976)