Aldinger v. Howard case brief

Aldinger v. Howard case brief

427 U.S. 1 (1976).

CASE SYNOPSIS: Petitioner employee sought certiorari review of the judgment of the United States Court of Appeals for the Ninth Circuit, which held that it did not have supplemental jurisdiction to hear the employee's civil rights action against respondent employer. The employee contended that she was discharged in violation of 42 U.S.C.S. § 1983 and that the courts had supplemental jurisdiction under 28 U.S.C.S. § 1343(3) to hear her case.

FACTS: An employee was terminated from her employment with a county. The employee filed an action asserting state and federal claims against the employer. The state-law claim rested on state statutes that waived the employer's sovereign immunity and provided for vicarious liability for the tortious conduct of its officials. The lower courts dismissed her 42 U.S.C.S. § 1983 claim because the county was not a person for the purpose of 28 U.S.C.S. § 1343, and dismissed the state claims for lack of jurisdiction.

HOLDING:

The court held that the lower courts properly determined that the federal claim failed because the employer was a county and, therefore, was not a person for the purpose of 42 U.S.C.S. § 1983.

ANALYSIS:
Therefore, the court held that the jurisdiction conferred by 28 U.S.C.S. § 1343(3) did not provide a source of pendent jurisdiction for the state-law claims. The court held that because there was no statutory claim upon which pendent jurisdiction over the state law claim could rest, the lower federal courts lacked jurisdiction over the state law claims.

CONCLUSION: The judgment of the court of appeals holding that federal courts lacked jurisdiction was affirmed.

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