Hagans v. Lavine
Annotate this Case
415 U.S. 528 (1974)
U.S. Supreme Court
Hagans v. Lavine, 415 U.S. 528 (1974)
Hagans v. Lavine
Argued December 11, 1973
Decided March 25, 1974
415 U.S. 528
Petitioners, recipients of public assistance under the federal-state Aid to Families with Dependent Children (AFDC) program, brought this action under 42 U.S.C. § 1983 and 28 U.S.C. § 2201 challenging a New York regulation permitting the State to recoup prior unscheduled payments for rent from subsequent grants under the AFDC program, on the ground that the regulation violated the Equal Protection Clause of the Fourteenth Amendment and conflicted with the Social Security Act and implementing regulations of the Department of Health, Education, and Welfare (HEW). Injunctive and declaratory relief was sought, and jurisdiction was invoked under 28 U.S.C. §§ 1343(3) and (4). The District Court declared the recoupment regulation contrary to the Social Security Act and HEW regulations, and enjoined its implementation or enforcement. The Court of Appeals reversed, holding that, because petitioners had failed to present a substantial constitutional claim, the District Court lacked jurisdiction to entertain either the equal protection or the statutory claim.
1. The District Court had jurisdiction under 28 U.S.C. § 1343(3). Pp. 415 U. S. 534-543.
(a) Section 1343(3) conferred jurisdiction to entertain the constitutional claim if it was of sufficient substance to support federal jurisdiction, in which case, the District Court could hear as a matter of pendent jurisdiction the claim of conflict between federal and state law without determining that the latter claim in its own right was encompassed with § 1343. P. 415 U. S. 536.
(b) Within the accepted substantiality doctrine, petitioners' complaint alleged a constitutional claim sufficient to confer jurisdiction on the District Court to pass on the controversy, since (1) the complaint alleged a deprivation, under color of state law, of constitutional rights within the meaning of §§ 1343(3) and
1983; (2) the equal protection issue was neither frivolous nor so insubstantial as to be beyond the District Court's jurisdiction, and the challenged regulation was not so clearly rational as to require no meaningful consideration; and (3) the cause of action alleged was not so patently without merit s to justify a dismissal for want of jurisdiction, Bell v Hood, 327 U. S. 678, whatever may be the ultimate resolution of the federal issues on the merits. Pp. 415 U. S. 536-543.
2. Given a constitutional question over which the District Court had jurisdiction, it also had jurisdiction over the "statutory" claim. The latter claim was to be decided first, and could be decided by the single district judge, while the constitutional claim could be adjudicated only by a three-judge court, and only if the statutory claim was previously rejected. Pp. 415 U. S. 543-545.
3. State law claims pendent to federal constitutional claims conferring jurisdiction on a district court generally are not to be dismissed. Given advantages of economy and convenience and no unfairness to litigants, they are to be adjudicated, particularly where they may be dispositive and their decision would avoid adjudication of federal constitutional questions. There are special reasons to adjudicate the pendent claim where, as here, the claim, although called "statutory," is in reality a constitutional claim arising under the Supremacy Clause, since "federal courts are particularly appropriate bodies for the application of preemption principles." Mine Workers v. Gibbs, 383 U. S. 715, 383 U. S. 729. Pp. 415 U. S. 545-550.
471 F.2d 347, reversed and remanded.
WHITE, J., delivered the opinion of the Court, in which DOUGLAS, BRENNAN, STEWART, MARSHALL, and BLACKMUN, JJ., joined. POWELL, J., filed a dissenting opinion, in which BURGER, C.J., and REHNQUIST, J., joined, post, p. 415 U. S. 550. REHNQUIST, J., filed dissenting opinion, in which BURGER, C.J., and POWELL, J., joined, post, p. 415 U. S. 552.
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