During revision of the District's alcoholic beverage laws, Council Member Adrian Fenty proposed a targeted four-year moratorium in part of Ward 4 banning retailers from breaking manufacturers' beer packages to sell a single container of 70 ounces or less. The revised moratorium zone encompassed all existing Ward 4 Class A and Class B liquor licensees, while singles sales remained permissible outside the zone and licensees could transfer licenses outside it. Plaintiffs, Ward 4 licensees, claimed the amendment violated the Home Rule Act's two-readings requirement and several provisions of the Fifth Amendment. The district court ruled for plaintiffs on the Home Rule Act claim without reaching the merits of the federal claims.
Issue
Whether the federal constitutional claims were substantial enough to support federal-question jurisdiction and, in turn, supplemental jurisdiction over the local Home Rule Act claim. If not, whether the district court lacked jurisdiction to decide the Home Rule Act issue.
Rule
Supplemental jurisdiction over a local-law claim exists only if the accompanying federal claims are substantial. If the federal claims are obviously frivolous or so attenuated and unsubstantial as to be absolutely devoid of merit, the federal court lacks subject-matter jurisdiction over both the federal claims and any local-law claims appended to them.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
The city council in Cleveland adopts an ordinance barring all 58 pawn shops in one district from staying open after 8 p.m. Nina Patel, who owns one of the shops, files in federal court asserting a state-law procedural challenge and a federal procedural due process claim based on the council's failure to give her an individual hearing before enactment.
Which is the strongest argument that the federal court lacks subject-matter jurisdiction over the state-law claim?
Explanation. A federal court may hear a local or state-law claim only if there is a substantial federal claim anchoring supplemental jurisdiction. A federal claim is not substantial if it is obviously frivolous or absolutely devoid of merit. Under the majority's reasoning, a generally applicable legislative rule affecting many persons falls within Bi-Metallic, so individualized hearings are not constitutionally required. Because that due process theory is plainly meritless, it cannot support supplemental jurisdiction over the state-law claim. (Derived from Decatur Liquors, Inc. v. District of Columbia (n.d.).)