Monday, February 11, 2013

Executive Software North America, Inc. v. United States District Court for the Central District of California case brief

Executive Software North America, Inc. v. United States District Court for the
Central District of California
case brief summary
24 F.3d 1545 

SYNOPSIS: Petitioners, an employer and related individuals, sought a writ of mandamus to an order of respondent United States District Court for the Central District of California remanding pendent state law claims by plaintiff employee, the real party in interest, in an employment discrimination suit.

-Plaintiff sued Defendant in state court for violations of Title VII and state claims for violation of the California Constitution and a California anti-discrimination statute.
-Defendant removed the case to federal court. The District Court remanded the supplemental state claims to state court, ruling, pursuant to [United Mine Workers v. Gibbs], that it had discretion to remand if: the state claims substantially predominate, the state claims involve novel or complex issues of law, consolidating the claims will likely result in jury confusion, or retention of the state claim will involve expending substantial judicial time and effort.
-Defendant petitioned the Court of Appeals for a writ of mandamus ordering the lower court to retain jurisdiction over the state law claims.

OVERVIEW: The employee filed federal and state law claims for employment discrimination against petitioners. Petitioners removed the action to federal court. When the district court remanded the pendent state law claims, petitioners requested a writ of mandamus.

The court granted the writ, holding that the district court clearly erred in not maintaining supplemental jurisdiction over the pendent state claims.

-The district court did not rely on the supplemental jurisdiction statute, 28 U.S.C.S. § 1367(c), in making its decision and failed to articulate how the circumstances that warranted declining jurisdiction were exceptional and compelling under the statute.
-The district court clearly erred by articulating a basis for declining jurisdiction that was unauthorized by statute.
-The district court's errors were significant and the question was an important question of first impression.
-Petitioners faced unrectifiable prejudice if not granted the writ and there were no other adequate means for relief.

In order for a court to decline to exercise jurisdiction over supplemental state law claims pursuant to 28 U.S.C. Section: 1367, the district court must find that one of the circumstances under 28 U.S.C. Section: 1367(c) exist and articulate the circumstances in the order declining jurisdiction.

OUTCOME: The court reversed, holding that the district court clearly erred when it relied on a basis for remanding pendent state claims that was not permitted by statute and failed to articulate its reasons for remanding the pendent claims.

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