## Facts

- In 1983, Barbara Finley’s husband and two children died when their airplane struck power lines while approaching a city-operated airfield in San Diego.
- Finley brought state-law negligence claims in state court against the City of San Diego and San Diego Gas & Electric Company (SDG&E) concerning the runway and power lines.
- After learning the Federal Aviation Administration (FAA) was responsible for certain runway lights, Finley filed a separate action in federal district court against the United States under the Federal Tort Claims Act (FTCA), alleging negligence in runway-light operation/maintenance and air-traffic-control functions.
- Finley moved to amend the federal complaint to add the City and SDG&E as additional defendants on state-law claims, despite no independent basis for federal jurisdiction over those parties.

## Issues

1. Whether the FTCA’s jurisdictional grant in 28 U.S.C. § 1346(b), covering “civil actions on claims against the United States,” permits pendent-party jurisdiction over additional nonfederal defendants when related state-law claims arise from the same facts.
2. Whether pendent or ancillary jurisdiction doctrines can extend an FTCA action to include nonfederal parties absent express congressional authorization.

## Decision

- The Supreme Court affirmed the Ninth Circuit.
- The Court held that the FTCA does not permit pendent-party jurisdiction over defendants other than the United States.
- The Court concluded that neither *Gibbs*’s “common nucleus of operative fact” approach nor ancillary-jurisdiction concepts could expand the FTCA’s limited statutory jurisdictional grant.
- As a result, the state-law claims against the City and SDG&E could not proceed in the same federal action as the FTCA claim against the United States.

## Legal Principles

- Federal court jurisdiction must rest on a statutory grant; it cannot be enlarged based on efficiency concerns.
- A jurisdictional grant limited to claims involving specified parties does not, without more, authorize jurisdiction over claims involving additional parties.
- Pendent-claim doctrine does not automatically extend to pendent-party jurisdiction; courts look for congressional authorization in the relevant jurisdictional statute.
- The FTCA’s language conferring jurisdiction over actions on claims “against the United States” does not reach claims against nonfederal defendants lacking an independent jurisdictional basis.
- The fact that FTCA claims must be brought in federal court does not, by itself, permit joining related state-law claims against nonfederal parties in the same federal suit.

## Conclusion

The Court ruled that the FTCA’s jurisdictional text authorizes federal jurisdiction only over claims against the United States, not related state-law claims against additional nonfederal defendants, even when all claims arise from the same incident.


Finley v. United States, 490 U.S. 545 (1989)