McCoy v. Iberdrola Renewables, Inc.

Dist. Ct. did not err in dismissing for failure to state cause of action third-party plaintiff’s counterclaims alleging contribution arising out of plaintiff’s personal injury claim, as well as claims alleging state and federal antitrust violations, even though third-party plaintiff essentially argued on appeal that Dist. Ct. lacked jurisdiction over state and federal antitrust counterclaims since said federal claims were “too weak” to invoke federal question jurisdiction under 28 USC section 1331, and that its state claims did not fall within scope of supplemental jurisdiction under 28 USC section 1367(a). Plaintiff’s federal antitrust claims that concerned alleged misuse of market power and alleged conspiracy with another entity were sufficient to invoke subject matter jurisdiction so as to permit Dist. Ct. ability to ultimately dismiss said claims. Moreover, Dist. Ct. could properly consider and dismiss instant state law counterclaims where they formed part of same case or controversy as federal antitrust counterclaims. Ct. noted, though, that counterplaintiff’s strategy on appeal of arguing lack of jurisdiction with respect to its own counterclaims placed counterplaintiff at risk for imposition of Rule 11 sanctions.