8. In a lawsuit with multiple parties or multiple claims, does the federal court have discretion to apply a doctrine of “pendent venue”? Commentators explain that under this doctrine, venue would “be proper so long as otherwise improperly venued claims are joined with a properly-venued claim and all arise out of a common nucleus of operative fact.” Steinman, Claims, Civil Actions, Congress & the Court: Limiting the Reasoning of Cases Construing Poorly Drawn Statutes, 65 Wash. & Lee L. Rev. 1593, 1655–56 (2008). Should application of the doctrine draw from the same considerations of party convenience373and judicial efficiency that inform supplemental jurisdiction under 28 U.S.C. § 1367? Are there constitutional differences? What problems do you foresee with recognizing a doctrine of pendent venue? See Corn, Pendent Venue: A Doctrine in Search of a Theory, 68 U. Chi. L.

Rev. 931 (2001).