On November 9, 1984, Larry Harvey (defendant), a police officer in the Town of Luray, Virginia, arrested Florhline Painter (plaintiff) for drunk driving. On April 9, 1985, Painter filed a complaint with the Luray Town Council, alleging that Harvey raped her and used excessive force against her at the time of the arrest. Painter also issued a written statement regarding her arrest to a local newspaper. In February 1985, Painter sued Harvey in federal district court, alleging that he had no probable cause to arrest her and that he had used excessive force against her in violation of 42 U.S.C. § 1983. Harvey filed a defamation counterclaim under state law, alleging that Painter had submitted false statements to the Luray Town Council and the newspaper. After trial, the jury found in favor of Harvey on both the § 1983 claim and the defamation counterclaim. Painter filed a motion to set aside the verdict, claiming that the court lacked supplemental subject matter jurisdiction over the state law counterclaim. The district court denied the motion, finding that Harvey’s counterclaim involved substantially the same evidence as Painter’s claim and was therefore compulsory. Painter appealed.