Satey v. JPMorgan Chase & Company

The Facts

Plaintiff obtained a credit card and used it for purchases costing a few hundred dollars. But about a month later, the appellee-company received a charge in the amount of $8,666.00 on plaintiff’s credit card and approved it. Plaintiff refused to pay the charge contending that he was a victim of identity theft. The appellee-company sold the unpaid debt to the debt collector. The case was reported to the agency. Even though plaintiff dismissed the claims against the debt collector and settled with the agency, he furthered his claim of identity theft.

Procedural History

The US Court of Appeals affirmed the judgment of the initial trial court.


According to California’s Identity Theft Law a victim of identity theft is entitled to bring an action for damages, civil penalties, and injunctive relief against a claimant to establish that the person is a victim of identity theft in connection with the claimant’s claim against that person [Cal. Civ. Code § 1798.93(a) and (c)].

As per 28 U.S.C.S. § 1367(c) a federal district court with power to hear state law claims has discretion to keep, or decline to keep.

The Issue

Whether district court did abuse its discretion by retaining supplemental jurisdiction over the state Identity Theft Law claim.

The Holding/Reasoning

The United States Court of Appeals held according to California’s Identity Theft Law a claim against a victim of identity theft may persist for four or more years. The court asserted that the statute of limitations will stay in force when a victim of identity theft keeps trying to seek relief under California’s Identity Theft Law, so long as original claimant or the new one maintains a claim.

The appellate court admitted that “pendent jurisdiction doctrine is designed to enable courts to handle cases involving state-law claims in the way that will best accommodate the values of economy, convenience, fairness, and comity. In the usual case in which all federal-law claims are eliminated before trial, the balance of factors to be considered under the pendent jurisdiction doctrine–judicial economy, convenience, fairness, and comity–will point toward declining to exercise jurisdiction over the remaining state-law claims. However, dismissal of the remaining state law claims in not “mandatory”.

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