Facts
- Carol and Jon Toberman sued several defendants in federal court for negligence and loss of consortium arising from injuries suffered in an automobile accident on the Pennsylvania Turnpike.
- Federal jurisdiction over the Tobermans’ suit was based on diversity of citizenship.
- One defendant, Richard Menendez, filed a third-party complaint under Federal Rule of Civil Procedure 14 against Timothy Swarthout and St. Johnsbury Trucking Company.
- Menendez sought to shift some or all of any liability to the third-party defendants, asserting claims commonly pleaded as contribution and/or indemnity arising from the same accident.
- The third-party defendants moved to dismiss (or, alternatively, for a more definite statement) under Rules 12(b)(1) and 12(b)(6), arguing the court lacked subject-matter jurisdiction over the third-party claims.
Issues
- Whether the federal court had subject-matter jurisdiction to hear a defendant’s Rule 14 third-party claims for contribution/indemnity in a diversity action when the third-party claims lacked an independent basis for federal jurisdiction.
- Whether 28 U.S.C. § 1367 (supplemental jurisdiction) permitted the court to keep the third-party claims despite the case’s diversity posture.
Decision
- The court denied the motion to dismiss for lack of subject-matter jurisdiction, holding that the third-party claims fell within the court’s supplemental jurisdiction because they arose from the same automobile accident and were part of the same Article III “case or controversy” as the main action.
- The court concluded that § 1367(b)’s limits in diversity cases did not strip jurisdiction over a defendant’s impleader claims under Rule 14; the statutory restriction is aimed at certain additional claims by plaintiffs, not a defendant’s third-party practice seeking liability over.
- Because subject-matter jurisdiction existed under § 1367(a), dismissal under Rule 12(b)(1) was not warranted; and the jurisdictional attack did not justify dismissal under Rule 12(b)(6).
Legal Principles
- Under 28 U.S.C. § 1367(a), a federal court with original jurisdiction may exercise supplemental jurisdiction over additional state-law claims that are so related to the claims in the action that they form part of the same case or controversy.
- Rule 14 impleader claims for contribution or indemnity arising from the same accident or occurrence ordinarily satisfy § 1367(a)’s “same case or controversy” requirement.
- In diversity cases, § 1367(b) withdraws supplemental jurisdiction over certain claims by plaintiffs against parties brought in under specified joinder rules, but it does not bar a defendant’s Rule 14 third-party claims seeking liability over.
- When supplemental jurisdiction applies, the third-party claim need not have an independent jurisdictional basis (such as complete diversity between the defendant and the third-party defendant) to remain in federal court.
Conclusion
Toberman v. Copas held that, in a diversity automobile-accident case, the court could hear a defendant’s Rule 14 third-party contribution/indemnity claims under supplemental jurisdiction because they arose from the same occurrence as the plaintiffs’ claims, and § 1367(b) did not remove jurisdiction over impleader claims asserted by a defendant.