June 26, 2019

Tenth Circuit: Issue of Federal Law Does Not Confer Federal Jurisdiction Over State Law Claims

The Tenth Circuit Court of Appeals issued its opinion in Becker v. Ute Indian Tribe of the Uintah and Ouray Reservation on Tuesday, October 21, 2014.

Plaintiff Lynn Becker contracted to provide services to the Ute Indian Tribe of the Uintah and Ouray Reservation related to its mineral and energy resource development. A dispute arose regarding Becker’s compensation under the contract, and he brought claims for breach of contract, breach of covenant of good faith and fair dealing, and accounting claims against the Tribe in the U.S. District Court for the District of Utah. The Tribe moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. The district court granted the Tribe’s motion to dismiss, because all Becker’s claims were state law claims.

Becker appealed, asserting that although his claims were state law claims, the district court had federal question jurisdiction because the case raised substantial issues of federal law. The Tenth Circuit disagreed, finding instead that the mere question of a federal issue in a state cause of action does not automatically confer federal question jurisdiction. The district court’s dismissal was affirmed.

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