OPINION
NGUYEN, Circuit Judge:
The common-law doctrine of ancillary jurisdiction over related claims, codified as part of a federal court's supplemental jurisdiction under 28 U.S.C. § 1367, is generally well understood. Yet, as the Supreme Court observed, the "doctrine of ancillary jurisdiction can hardly be criticized for being overly rigid or precise," because the more obscure doctrine of ancillary jurisdiction over collateral proceedings...
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