Wading in Erie's Murky Waters: A Federal Court's Constitutional Duty to Deny Supplemental Jurisdiction When Faced with a Conflict of Privilege Law

The article addresses the constitutional duty of federal courts to navigate conflicts between federal and state privilege laws when exercising supplemental jurisdiction. It argues that Federal Rule of Evidence 501 does not provide clear guidance on this issue, leading to potential violations of federalism principles. The analysis advocates for a cautious approach, urging federal courts to avoid overriding state privilege laws and to consider declining supplemental jurisdiction when necessary to respect state sovereignty and avoid constitutional conflicts.