Jinks v. Richland County

538 U.S. 456 (2003)

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Nature of the Case

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Facts

On October 14, 1994, Carl was arrested and jailed for failure to pay child support. Four days later, while confined he died of complications associated with alcohol withdrawal. In 1996, within the applicable statute of limitations, P brought an action in the United States District Court asserting a cause under § 1983, and also supplemental claims for wrongful death and survival under the South Carolina Tort Claims Act. The District Court granted D's motion for summary judgment on the § 1983 claim. It then issued an order declining to exercise jurisdiction over the remaining state-law claims, dismissing them without prejudice pursuant to 28 U.S.C. § 1367(c)(3). On December 18, 1997, P filed her wrongful death and survival claims in state court. The jury returned a verdict of $80,000 for P. The South Carolina Supreme Court reversed on the ground that P's state-law claims were time-barred. The state supreme court held that §1367(d) was unconstitutional as applied to claims brought in state court against a State's political subdivisions because it 'interferes with the State's sovereign authority to establish the extent to which its political subdivisions are subject to suit.' P appealed.