## Facts

- Sylvester Griffin, a Mississippi citizen and trust beneficiary, sued a trustee and related defendants in Louisiana state court seeking trust reformation and asserting state-law claims including fraud.
- Defendants removed the action to the U.S. District Court for the Western District of Louisiana solely under diversity jurisdiction (28 U.S.C. § 1332).
- The district court granted summary judgment to defendants and dismissed Griffin’s claims with prejudice, entering judgment in defendants’ favor.
- After withdrawing as Griffin’s counsel, Robert A. Lee (a Louisiana citizen) moved to intervene as of right under Federal Rule of Civil Procedure 24(a)(2) to recover attorney’s fees and costs under a contingency-fee agreement and Louisiana’s attorney-lien statute (La. Rev. Stat. § 37:218).
- The district court permitted Lee’s intervention and, after a bench trial, awarded Lee $16,068 in attorney’s fees based on the agreement.
- Griffin appealed the fee award; the Fifth Circuit ordered supplemental briefing on whether the district court had subject-matter jurisdiction over Lee’s intervention claim.

## Issues

1. Whether, in a case in federal court solely under diversity jurisdiction, the district court could exercise supplemental jurisdiction under 28 U.S.C. § 1367 over an attorney’s Rule 24 intervention claim for fees against the client.
2. Whether § 1367(b) bars supplemental jurisdiction over a Rule 24 intervenor’s claim when the claim does not independently satisfy § 1332’s jurisdictional requirements, including the amount in controversy.

## Decision

- The Fifth Circuit held the district court lacked supplemental jurisdiction over Lee’s intervention claim under 28 U.S.C. § 1367(b).
- The court vacated the fee judgment and remanded with instructions to dismiss the petition of intervention for lack of subject-matter jurisdiction.
- The court resolved the appeal on jurisdictional grounds without reaching the merits of the fee dispute.

## Legal Principles

- Federal courts have an independent duty to examine subject-matter jurisdiction, including on appeal and even if not raised by the parties.
- In cases where original jurisdiction rests solely on diversity (§ 1332), § 1367(b) withdraws supplemental jurisdiction over certain claims by parties seeking to intervene under Rule 24 when exercising jurisdiction would be inconsistent with § 1332’s requirements.
- An intervenor’s state-law claim for attorney’s fees in a diversity case cannot proceed on a supplemental basis if it would circumvent § 1332’s limitations, including the amount-in-controversy requirement.

## Conclusion

The Fifth Circuit vacated an attorney’s fee award obtained through Rule 24 intervention in a diversity-only case, holding that § 1367(b) barred supplemental jurisdiction over the intervenor’s fee claim and requiring dismissal for lack of subject-matter jurisdiction.


Griffin v. Lee, 621 F.3d 380 (5th Cir. 2010)