Constitutional Law Keyed to Farber
Jinks v. Richland County
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Susan Jinks (plaintiff) brought a wrongful death action and a civil rights claim against Richland County (defendant) in federal court after her husband died in the county detention center. The federal court had jurisdiction over the civil rights claim, which was grounded in federal law, and exercised supplemental jurisdiction over the wrongful death claim, which was grounded in state law. Section 1367 of the U.S. Judicial Code allows federal courts to exercise supplemental jurisdiction over state law claims—claims that they ordinarily would not have the authority to review—if there is a related federal claim for which there is independent jurisdiction. In this case, the district court awarded summary judgment to the county on the civil rights claim. The district court then dismissed the wrongful death claim under § 1367(c), which requires federal courts to dismiss supplemental claims if all federal claims have been dismissed. Jinks took her wrongful death action to state court, where the jury ruled in her favor. The South Carolina Supreme Court reversed the jury verdict, holding that Jinks did not bring her claims within the prescribed state statute of limitations. The state supreme court also held that § 1367(d) of the U.S. Judicial Code, which states that the period of limitations for supplemental claims to be refiled in state court is tolled while such claims are pending in federal court, does not preempt South Carolina’s statute of limitations.
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