Jinks v. Richland County

Susan Jinks (plaintiff) sued Richland County (defendant) in federal court, bringing both a federal civil rights claim (over which the court had independent jurisdiction) and a related state-law wrongful death claim (over which it exercised supplemental jurisdiction under 28 U.S.C. section 1367) after her husband died in the county detention center. The district court granted the county summary judgment on the civil rights claim and then dismissed the wrongful death claim under section 1367(c), which requires dismissal of supplemental claims once all independent federal claims are gone; Jinks refiled the wrongful death claim in state court and won at trial, but the South Carolina Supreme Court reversed, holding the claim was untimely under the state statute of limitations and that section 1367(d)'s tolling provision - which tolls the limitations period for supplemental claims while pending in federal court - did not preempt that state limitations period.