Mikel Mims v. United States

“The power to hear and determine a cause is jurisdiction.” United States v. Arredondo, 31 U.S. 691, 709 (1832). And “federal district courts have only such jurisdiction as is provided, in terms, by the Constitution or a statute.” Warren G. Kleban Eng’g Corp. v. Caldwell, 490 F.2d 800, 802 (5th Cir. 1974). Though there is a “limited exception” for “ancillary jurisdiction,” id., that doctrine is a “creature of necessity,” requiring proof of some “practical need to protect legal rights” of a party. Peacock v. Thomas, 516 U.S. 349, 356, 359 (1996) (citation omitted). Therefore, the petitioner presents the following question: May a district court rely exclusively on the ancillary jurisdiction doctrine to enforce a restitution judgment notwithstanding the existence of legislation independently authorizing that very act?