Iglesias v. Mutual Life Insurance Co.
United States Court of Appeals for the First Circuit
156 F.3d 237 (1998)
Iglesias (plaintiff) sued his former employer, Mutual Life (defendant), in diversity for discrimination and breach of contract, but during discovery admitted he had defrauded Mutual Life through inflated expense vouchers; Mutual Life then counterclaimed for restitution under state law, though it never made clear whether the counterclaim independently satisfied diversity jurisdiction's $50,000 amount-in-controversy minimum. The district court granted Mutual Life summary judgment on Iglesias's claims and dismissed the counterclaim as untimely, and both parties appealed.
Whether Federal Rule of Civil Procedure 13 gives a federal court supplemental subject-matter jurisdiction to hear compulsory or permissive counterclaims.