## Facts

- Jerry Palmer sued a Georgia hospital authority and a treating physician (and the physician’s professional corporation) after the death of his wife, Paulette Palmer, and their unborn child.
- The complaint asserted a federal claim under EMTALA (42 U.S.C. § 1395dd) and multiple Georgia-law claims, including wrongful death and medical malpractice.
- Intervening authority confirmed EMTALA provides a private cause of action against hospitals, not treating physicians.
- The district court dismissed the EMTALA claim against the physician and dismissed all state-law claims against the physician for lack of subject-matter jurisdiction; claims against the hospital proceeded separately.

## Issues

1. Whether 28 U.S.C. § 1367(a) gave the district court statutory authority to exercise supplemental jurisdiction over state-law claims against the physician, despite dismissal of the only federal claim against that defendant and lack of diversity.
2. Whether the district court properly exercised discretion under 28 U.S.C. § 1367(c) in declining (or dismissing for lack of) supplemental jurisdiction over those state-law claims.

## Decision

- The Eleventh Circuit agreed diversity jurisdiction was absent.
- The court held § 1367(a) authorized supplemental jurisdiction over the state-law claims against the physician because they arose from the same case or controversy as the federal EMTALA claim within the court’s original jurisdiction when filed.
- The court held dismissal of the federal claim against a particular defendant did not automatically eliminate supplemental jurisdiction over related state-law claims against that defendant.
- The court reversed the dismissal of the claims against the physician and remanded because the district court did not perform the required § 1367(c) discretionary analysis.

## Legal Principles

- Under 28 U.S.C. § 1367(a), when a federal court has original jurisdiction over at least one claim, it may exercise supplemental jurisdiction over additional claims and additional parties forming part of the same Article III case or controversy.
- Failure of a federal claim on the merits (including lack of a cause of action under the federal statute) does not retroactively erase supplemental jurisdiction that attached at filing.
- Once § 1367(a) is satisfied, dismissal of supplemental state-law claims is governed by discretion under § 1367(c), not by an automatic jurisdictional bar.
- A district court must apply the § 1367(c) framework and articulate whether a statutory ground for declining supplemental jurisdiction applies, considering traditional factors such as judicial economy, convenience, fairness, and comity.

## Conclusion

The Eleventh Circuit held the district court had supplemental jurisdiction under § 1367(a) over state-law claims against the treating physician even after the EMTALA claim against that physician was dismissed, and it remanded because the district court failed to decide—under § 1367(c)—whether to retain or decline those claims as a discretionary matter.


Palmer v. Hosp. Auth. of Randolph Cnty., 22 F.3d 1559 (11th Cir. 1994)