Finley v. United States is a significant Supreme Court decision that shaped how federal courts interpret jurisdiction under the Federal Tort Claims Act (FTCA). The ruling addressed whether a plaintiff who brings an FTCA claim in federal court may join additional defendants for whom there is no independent basis of federal jurisdiction. The outcome of the case later prompted Congress to enact a statutory fix through 28 U.S.C. § 1367, the modern supplemental jurisdiction statute.
This case arose from a tragic airplane crash in 1983 involving Barbara Finley’s family. As the legal proceedings unfolded, the Supreme Court used this dispute to clarify the reach of federal jurisdiction under the FTCA.
The decision is now widely cited for its strict interpretation of statutory jurisdiction and for its influence on Congress’s later reforms. The following case brief provides a detailed explanation of the facts, procedural history, issue, decision, reasoning, dissents, and aftermath of Finley v. United States.
Facts of Finley v. United States
In 1983, Barbara Finley’s husband and two of their children were flying into San Diego, California. During the aircraft’s approach, it collided with electric transmission lines, causing the plane to crash. No one survived the accident. The crash triggered questions about which entity or entities were responsible for the conditions that led to the collision.
Finley filed a lawsuit in California state court. She alleged that San Diego Gas and Electric Company had been negligent in illuminating the transmission lines and that the City of San Diego had been negligent in maintaining the runway lights.
These claims were based entirely on state law. Later, Finley discovered that the Federal Aviation Administration (FAA) was actually responsible for maintaining the runway lights at the time of the crash.
Because claims against the federal government must be brought in federal court under the FTCA, Finley filed a separate lawsuit in the United States District Court for the Southern District of California, naming the United States as a defendant. Her federal complaint asserted that the court had jurisdiction under the FTCA.
Soon after, Finley amended her federal complaint in an effort to join the state-law defendants—San Diego Gas and Electric Company and the City of San Diego—to her federal suit. However, there was no independent jurisdictional basis to bring these additional defendants into federal court. They were not federal entities, and the claims against them did not arise under federal law.
Procedural History
The District Court granted Finley’s motion to add the state-court defendants based on a theory of supplemental jurisdiction similar to the approach used in United Mine Workers of America v. Gibbs. Under that doctrine, a federal court could hear state-law claims arising from a “common nucleus of operative fact” when they are part of the same case or controversy.
The United States appealed, arguing that the FTCA did not authorize federal courts to exercise pendent-party jurisdiction. The appellate court reversed, holding that there was no statutory authority to join additional parties when the FTCA was the only basis for federal jurisdiction.
The Supreme Court granted certiorari to resolve whether the FTCA allows supplemental jurisdiction over additional defendants for whom no independent federal jurisdiction exists. Thus, the dispute in Finley v. United States centered on the scope of federal judicial authority and how strictly courts must interpret statutes granting jurisdiction.
Issue
Does the Federal Tort Claims Act permit federal courts to exercise supplemental (also known as pendent-party) jurisdiction over additional defendants when there is no independent basis for federal jurisdiction over those defendants?
This question required the Court to interpret the FTCA’s jurisdictional provisions and to determine whether the statute implicitly allowed federal courts to add parties simply because their conduct formed part of the same factual scenario as the FTCA claim.
Finley v. United States Judgment
The Supreme Court held that the FTCA does not permit pendent-party jurisdiction. According to the majority, the FTCA provides jurisdiction only over the United States. It does not authorize federal courts to hear claims against additional defendants who do not independently qualify for federal jurisdiction.
Justice Scalia, writing for the majority, relied on a textual reading of the statute. He quoted Chief Justice Marshall’s view that two conditions are necessary for federal jurisdiction: the Constitution must authorize the court to hear the case, and an act of Congress must grant the court jurisdiction.
Because the FTCA does not expressly authorize jurisdiction over additional parties, the Court concluded that federal courts cannot expand jurisdiction beyond what Congress has clearly provided.
Reasoning in Finley v. United States
In analyzing jurisdiction, the majority emphasized consistency in statutory interpretation. Justice Scalia explained that Congress must be able to rely on predictable, text-based interpretations of jurisdictional statutes. The Court therefore refused to infer jurisdiction where Congress had not clearly provided it.
The Court distinguished its earlier decision in United Mine Workers v. Gibbs, noting that Gibbs involved a broad statutory grant of federal jurisdiction and allowed federal courts to hear related state-law claims within the same case. However, Gibbs did not address pendent-party jurisdiction—that is, jurisdiction over an additional party against whom no independent federal jurisdiction exists.
In Finley v. United States, the majority concluded that the FTCA’s jurisdictional grant was narrow. It gave federal courts jurisdiction to hear claims against the United States—but nothing more. Because Congress had not provided statutory authority to join additional defendants, the federal court lacked jurisdiction over the state-law defendants.
Dissent
Two justices dissented: Justice Stevens and Justice Blackmun.
Justice Blackmun argued that pendent-party jurisdiction was practical and consistent with the needs of modern litigation. He believed that when a plaintiff is already required to bring an FTCA claim in federal court, it makes sense to allow related claims against other defendants to proceed in the same action.
Justice Stevens emphasized that for many years federal courts had exercised pendent-party jurisdiction in similar cases without objection from Congress. In his view, this long history, combined with Congress’s silence, suggested that the practice was acceptable. He also criticized the majority’s approach for forcing plaintiffs to litigate related claims in multiple courts, increasing inefficiency and hardship.
Both dissents stressed that allowing pendent-party jurisdiction would enable courts to resolve disputes more completely and fairly.
Aftermath
The decision in Finley v. United States highlighted a gap in federal jurisdictional statutes. In response, Congress enacted 28 U.S.C. § 1367 in 1990 as part of the Civil Justice Reform Act. Section 1367 codifies supplemental jurisdiction and expressly authorizes federal courts to hear claims involving additional parties when the claims form part of the same case or controversy.
This statute effectively overturned the result in Finley v. United States by giving federal courts broad authority to hear related claims involving additional parties, provided that certain conditions are met. Section 1367 remains the controlling law on supplemental jurisdiction today.
Conclusion
Finley v. United States is a landmark case that narrowed the scope of federal jurisdiction under the FTCA. By holding that federal courts lacked pendent-party jurisdiction absent explicit statutory authorization, the Supreme Court adopted a strict textual approach.
Though the decision limited the ability of plaintiffs to consolidate related claims in federal court, it also prompted Congress to enact a comprehensive supplemental jurisdiction statute. As a result, Finley v. United States continues to be central to understanding both the limits of statutory jurisdiction and the legislative response that expanded it.