Cohen v. Postal Holdings, LLC, No. 16-2657 (2d Cir. 2017)Annotate this Case
The Second Circuit vacated the district court's order granting summary judgment for Postal Holdings on Connecticut state law claims of private nuisance and negligence brought by plaintiffs. The court remanded with instructions to dismiss plaintiffs' First Amended complaint for lack of supplemental jurisdiction because a federal district court cannot exercise supplemental jurisdiction over state law claims unless it has subject matter jurisdiction over the federal claims originally presented. In this case, under the Contract Disputes Act, 41 U.S.C. 7101–7109, the district court lacked subject matter jurisdiction over Postal Holdings' Third Party Complaint. Therefore, the district court correctly dismissed the Third Party Complaint and thus lacked supplemental jurisdiction over plaintiffs' state law claims.