This comment examines the development of supplemental jurisdiction as applied to counterclaims, as well as the circuit slit with regard to supplemental jurisdiction over permissive counterclaims.
Beck, Graham M.
"Supplemental Jurisdiction over Permissive Counterclaims in Light of Exxon v. Allapattah,"
University of San Francisco Law Review: Vol. 41
, Article 2.
Available at: https://repository.usfca.edu/usflawreview/vol41/iss1/2