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Federal Court  Jurisdiction
Duty to Adjudicate Claim

Duty to Adjudicate Claim:
Federal Courts have obligation to adjudicate claims within their jurisdiction

 

Court: U.S. 9th Circuit Court of Appeals
Topic: Administrative Law, Civil Procedure, ERISA, Labor & Employment Law
Title:

FUNKHOUSER v. WELLS FARGO BANK

Date: 05/15/02
Case Number: 00-35397, 00-35410 (00-35397, 00-354100-5/15/02)
Summary:

However, the district court had jurisdiction to consider whether the claim was completely preempted by ERISA. See id. at 943 n.7. If a claim is completely preempted by ERISA, then the claim arises under federal law within the meaning of 28 U.S.C. § 1331. See, e.g., Toumajian v. Frailey, 135 F.3d 7029 648, 655 (9th Cir. 1998). The district court was obligated to consider complete preemption to determine whether a federal question existed. If the state claim were completely preempted, the district court would have had federal question jurisdiction over the claim and would not have had discretion to dismiss the claim instead without prejudice. See, e.g., New Orleans Pub. Serv., Inc. v. Council of New Orleans , 491 U.S. 350, 359 (1989) ("[T]he federal courts' obligation to adjudicate claims within their jurisdiction [is] virtually unflagging." (internal quotation marks omitted)). On the other hand, if the claim were not completely preempted, the court would be free to dismiss without prejudice under the supplemental jurisdiction statute. See 28 U.S.C. § 1367(c); see also Acri v. Varian Assocs., 114 F.3d 999, 1000 (9th Cir. 1997) (en banc). The district court consequently had jurisdiction to consider complete preemption.

A federal court had jurisdiction to rule that ERISA completely pre-empted a state law claim, even when the court ultimately declined to exercise supplemental jurisdiction after appellants failed to state a federal claim under the Family Leave Medical Act.

FUNKHOUSER v. WELLS FARGO BANK00-35397, 00-35410-05/15/02-ERISA jurisdiction


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