Supreme Court of the United States

Peacock v. Thomas

February 21, 1996516 U.S. 349

Summary

The Court, in an opinion by Justice Thomas joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, Kennedy, Souter, Ginsburg, and Breyer, held that federal courts lack ancillary jurisdiction over a new lawsuit seeking to impose an existing federal money judgment on a person not already liable for it. Thomas's complaint also supplied no independent federal jurisdiction because it alleged no underlying violation of ERISA or an ERISA plan; veil piercing alone was not an ERISA cause of action. The Court reversed the Fourth Circuit's judgment. Justice Stevens dissented alone, concluding that continuing enforcement jurisdiction permitted relief against a person who fraudulently diverted the judgment debtor's assets. He would have modified the excessive relief rather than denied jurisdiction altogether.

Holding

  • Whether the subsequent action independently arose under ERISA.. Neither ERISA's jurisdictional provision nor general federal-question jurisdiction supported this action because the complaint alleged no underlying violation of ERISA or an ERISA plan.
  • Whether factual interdependence with the original ERISA action supplied ancillary jurisdiction.. The original action did not supply ancillary jurisdiction over the subsequent lawsuit, which lacked an independent jurisdictional basis and involved insufficiently interdependent facts.
  • Whether ancillary enforcement jurisdiction authorized imposing the existing judgment on Peacock.. The District Court lacked ancillary enforcement jurisdiction over this new action seeking to make Peacock personally liable for Tru-Tech's existing ERISA judgment.

Docket 94-1453

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