Whether a federal court may exercise supplemental jurisdiction over state-law claims when it determines after trial that a plaintiff lacks standing to pursue its federal claims

QUESTION PRESENTED In a long line of cases, this Court has recognized that federal courts may continue to exercise supplemental jurisdiction over state-law claims when significant proceedings have taken place in the federal court before federal jurisdiction is found to be lacking. Here, after eight years of litigation, a ten-day trial, and an appeal, the Seventh Circuit found that the plaintiffs failed to prove at trial that they had suffered a concrete injury under the Fair Credit Reporting Act (“FCRA”) and, thus, under Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016), they lacked Article III standing. Therefore, the Seventh Circuit held, it had no jurisdiction over plaintiffs’ FCRA claims. Although in its initial opinion, the Seventh Circuit had held that the plaintiffs’ state-law defamation claims failed for the same reason as their FCRA claims — they failed to prove any injury at trial — in its amended opinion the Seventh Circuit did not direct the district court to enter judgment on the defamation claims for Allstate Insurance Company (“Allstate”). Instead, it ordered that the defamation claims be dismissed without prejudice, permitting plaintiffs to refile the claims in state court. The Seventh Court held that because the plaintiffs had no Article III standing to bring their federal FCRA claims, the court could not exercise supplemental jurisdiction over the defamation claims. The question presented is whether a federal court may exercise supplemental jurisdiction over state-law claims when it determines after trial that a plaintiff lacks standing to pursue its federal claims.