Where a supplemental proceeding was so independent from the initial proceeding that it constituted a separate dispute, it required an independent basis for subject-matter jurisdiction.The 7th U.S. Circuit Court of Appeals affirmed a decision by U.S. District Judge Thomas M. Durkin.Syed Rizvi and his company, Prime Builders & Development Inc., performed repair work for Mirza Alikhan, whose house had been damaged in a fire. When the work was completed in 2009, Alikhan paid Rizvi only part of what he owed.Rizvi sued for …