Legal Memorandum: Exclusive Jurisdiction

Issue: In Tennessee, does the federal district court have jurisdiction over state law claims?

Although the federal district courts are empowered with the authority to hear state law claims pendent to federal claims arising out of the same set of facts, Beddingfield v. City of Pulaski, 666 F. Supp. 1064, 1066-67 (M.D. Tenn. 1987), § 29-20-307 of the Tennessee Governmental Tort Liability Act (the “Act”) specifically states that the Tennessee circuit courts have exclusive, original jurisdiction over actions filed under the Act, Tenn. Code § 29-20-307 (Supp. 1999).  Because the Act removes governmental immunity for injuries caused by negligence, id. § 29-20-205 (Supp. 1999), actions for negligence against governmental entities must be filed in state court, Beddingfield, 666 F. Supp. at 1066-67.  “[A]s a matter of judicial power pendent jurisdiction probably cannot stand in the face of the limitations upon suability specified in Tenn. Code § 29-20-307.”  Id. at 1067.  In a state-law claim pendent to a claim under 42 U.S.C. § 1983 (Supp. 2000), the federal court is obligated to apply the limitation on state governmental liability set forth in the Act.  Id. (noting that even if the federal court had the authority to hear the pendent state law claims, it would exercise its discretion and decline jurisdiction).

In Beddingfield, the plaintiff asserted claims for wrongful death and violation of the state Constitution pursuant to state law, which claims were pendent to the § 1983 claim.  Id. at 1065. 

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