United States Court of Appeals For the Seventh Circuit ____________________ No. 23-1648 CONTINENTAL INDEMNITY COMPANY, individually and as subrogee of The Linn Contracting Companies, Inc., Plaintiff-Appellant,

v. BII, INC., an Illinois Corporation doing business as Paramount Post, Defendant,

and STARR INDEMNITY & LIABILITY CO., Garnishee-Appellee. ____________________

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:18-cv-05520 — Rebecca R. Pallmeyer, Chief Judge. ____________________

ARGUED JANUARY 25, 2024 — DECIDED JUNE 12, 2024 ____________________

Before HAMILTON, BRENNAN, and KIRSCH, Circuit Judges. HAMILTON, Circuit Judge. Plaintiff-appellant Continental Indemnity Company secured a default judgment for 2 No. 23-1648 $607,712.12 against defendant BII, Inc. arising from an injury to a worker at a construction site. Continental sought to col- lect on the judgment by adding appellee Starr Indemnity & Liability Company to the action as a garnishee using Illinois state law procedures under Federal Rule of Civil Procedure 69(a). Starr denied that its insurance contract with BII covered the workers’ compensation claim that was the subject of Con- tinental’s default judgment against BII. The district court found that adjudicating the disputed scope of coverage under the Starr-BII insurance policy was outside its subject matter jurisdiction because it was too distinct, factually and legally, from the underlying suit between Continental and BII. The district court dismissed the proceeding against garnishee Starr, and Continental has appealed. We must confess some uncertainty about the purpose of this appeal. As the district court explained, if Continental wants a federal forum to litigate this dispute with Starr, that forum is available for the price of filing one new civil action in the Northern District of Illinois. Still, Continental had the right to appeal, and we are obliged to decide it. As we explain below, we agree with the district court and affirm its dismissal for lack of jurisdiction. At bottom, the appeal turns on the scope of a federal court’s ancillary jurisdiction in the context of Rule 69 post- judgment enforcement efforts. Precedents from the Supreme Court and this circuit make clear the general principle that federal courts have ancillary enforcement jurisdiction to con- sider proceedings collateral to an underlying suit, but the sub- ject of those proceedings must still be sufficiently related to the facts and legal issues of the original action. Attempting to adjudicate new issues of liability against new parties falls No. 23-1648 3 outside the scope of ancillary enforcement jurisdiction and therefore cannot be done through certain enforcement pro- ceedings under Rule 69. But at the end of the day, whether a proceeding falls into a federal court’s ancillary jurisdiction will be a case-by-case, fact-dependent inquiry. I. Facts and Procedural History A. The Injury to Mr. Lumpkins On August 19, 2016, Alfred Lumpkins was injured while working for defendant BII on a construction site on South Maplewood Street in Chicago, Illinois. In early June 2016, Linn-Mathes, a general contractor, had contracted with BII to perform post-construction cleaning work at the Maplewood Street site. The contract between Linn-Mathes and BII required BII to maintain insurance, including workers’ compensation coverage, because it was responsible for the safety of its employees at the Maplewood Street site. After his injury, Mr. Lumpkins filed a