MCI v. Logan Group, Inc.
United States District Court for the Northern District of Texas
848 F.Supp 86 (1994)
MCI Telecommunications Corporation (MCI) (plaintiff) sued The Logan Group and Communications Specialties, Inc. (CSI) for unpaid telephone services. Fidelity, as assignee of CSI's accounts receivable, intervened, claiming MCI had assured it that CSI's accounts would be paid but then failed to pay, and asserting breach-of-contract, fraud, and estoppel claims against MCI. Although Fidelity styled its claims as raising federal questions, they were actually rooted in state law, and there was no diversity jurisdiction since both Fidelity and MCI were incorporated in Delaware; the court ordered Fidelity to establish a proper jurisdictional basis.
Whether, under 28 U.S.C. § 1367, a voluntarily intervening plaintiff may assert supplemental jurisdiction over claims based in state law if there is no diversity of citizenship.