Federal Jurisdiction–Pendent Claims–Doctrine of Pendent Jurisdiction Applies to Claim of Second Plaintiff–Wilson v. American Chain & Cable co.; Newman v. Freeman

In Wilson v. American Chain & Cable Co., plaintiff, whose son was injured by a defective lawnmower, brought a diversity action in federal district court on behalf of his son against the manufacturer, alleging damages in excess of the $10,000 jurisdictional minimum. Simultaneously, plaintiff sought recovery in his own name for medical bills and the expense of orthopedic shoes resulting from the injury. Because the latter claim was for less than $10,000, it was dismissed by the district court for lack of subject matter jurisdiction. On appeal to the Third Circuit, held, inter alia, the claim of the father was erroneously dismissed. Where two claims arising from the same injury are brought on behalf of two members of the same household, but only one claim satisfies the requisite jurisdictional amount, the doctrine of pendent jurisdiction may properly be invoked to eliminate the normal requirement that each claim independently meet the jurisdictional standard.