Heaton v. Adams

Background

Timothy Heaton, Ayesha Shaheed, John Latham, Aaron Leizerovici, Devin Reilly, Jack Wei Lin, Keith Karaha, and Carin Rosado sued Eric Adams, Jay Varma, Michele Morse, the New York City Department of Health & Mental Hygiene, the New York City Board of Health, Robert Tucker, the City of New York, and unidentified defendants. The plaintiffs alleged that they were former New York City Fire Department employees who refused a municipal COVID-19 vaccination mandate because of sincere religious beliefs opposing vaccination. They alleged that they were terminated between February and August 2022 and were not given judicial hearings before their terminations.

The original complaint asserted claims under 42 U.S.C. § 1983 for alleged violations of the First, Ninth, and Fourteenth Amendments, along with claims under New York State and New York City human-rights laws, the New York Constitution, New York Public Health Law § 2805-d, and their public employment contracts. The action was filed in New York State Supreme Court, Bronx County, on December 18, 2024, and was removed to this Court the next day.

Amended Complaint and Remand Request

At an initial pretrial conference on March 12, 2025, the Court denied the plaintiffs’ earlier motion to remand and their motion to sever the state-law claims. The plaintiffs renewed their request to remand after filing an amended complaint on April 15, 2025. The amended complaint eliminated the federal constitutional claims and left only state-law claims. On May 1, 2025, defense counsel informed the Court that the defendants consented to remand because no federal questions remained.

Court’s Analysis

Federal courts may exercise supplemental jurisdiction over related state-law claims when those claims are part of the same constitutional case or controversy as claims within federal jurisdiction. The Court relied on the Supreme Court’s statement that when an amended complaint removes the federal claims that supported removal, the federal court loses supplemental jurisdiction over the related state-law claims and must remand the matter to the state court where it began.

Because the amended complaint alleged no claims arising under federal law, Judge Jeannette A. Vargas concluded that this Court could not exercise supplemental jurisdiction over the remaining state-law claims. The Court also noted that the case was still in its early stages and that the defendants consented to remand.

Disposition

The action was REMANDED to the New York State Supreme Court, Bronx County. The Clerk was directed to send a copy of the order to that court and close the federal action. All pending motions were terminated. The order did not decide the merits of the plaintiffs’ state-law claims or the allegations underlying the original federal claims.