This case involved the scope of federal courts’ supplemental jurisdiction over state-law claims related to nuclear materials. The district court had held that under the Price-Anderson Act (PAA), federal jurisdiction requires an indemnity agreement, since the statute limits federal jurisdiction to causes of action arising out of a "nuclear incident," defined by the PAA as an "occurrence" happening away from the contract location specified "in the applicable indemnity agreement."
On review, the Eighth Circuit reversed the district court and held that the PAA grants federal courts supplemental jurisdiction over all cases arising out of "nuclear incidents," regardless of whether the nuclear material in question is subject to an indemnity agreement. The panel noted that the term "nuclear incident" is defined by the PAA as an "occurrence" and reasoned that the word "occurrence" should be interpreted according to its plain meaning, which is "something that takes place." Therefore, the panel concluded that a "nuclear incident" should be defined as "something that takes place within the United States." Under this broad definition of "nuclear incident," the panel determined that the federal district court possessed supplemental jurisdiction over the relevant claims, despite the absence of an indemnity agreement, because they arose from something that took place in the United States.
