Moore v. New York Cotton Exchange
United States Supreme Court
270 U.S. 593 (1926)
The New York Cotton Exchange (defendant) refused to supply cotton-price quotations to the Odd-Lot Cotton Exchange, believing it a fraud-tainted successor entity; Odd-Lot's president Moore (plaintiff) sued in federal court alleging an antitrust monopoly over cotton quotations and seeking an injunction requiring their delivery. The New York Exchange's answer counterclaimed that Odd-Lot had nevertheless obtained the quotations through unauthorized means and used them fraudulently, seeking its own injunction; the district court granted the Exchange's counterclaim injunction and eventually dismissed Odd-Lot's antitrust claim, and Odd-Lot appealed the counterclaim ruling, arguing it did not arise from the same transaction and lacked independent jurisdictional grounds.
Whether, for purposes of supplemental jurisdiction, a counterclaim that alleges, in part, the same essential facts as the original complaint arises out of the same transaction that is the subject matter of the complaint.