Thomas v. The Regents of the University of California
- Susan Illston
- 3:19-cv-06463
- U.S. District Court · Northern District of California
- 1
In Thomas v. Regents, Judge Illston granted Thomas’s motion and amended the judgment to dismiss state-law claims without prejudice.
Renee Thomas’s state-law claims against The Regents of the University of California and the other defendants were dismissed without prejudice after the court declined supplemental jurisdiction.
What happened
In Thomas v. The Regents of the University of California, Renee Thomas asked the court to change an earlier judgment that dismissed her state-law claims with prejudice. She argued those claims raised issues separate from her federal Title IX claims.
Thomas asked the court to decline supplemental jurisdiction, which would allow her to pursue the state-law claims in state court. She cited, among other issues, the “special relationship” doctrine in connection with her breach-of-fiduciary-duty claim.
Judge Susan Illston granted the motion to alter or amend. The court amended its earlier order and judgment to decline supplemental jurisdiction over the state-law claims and clarify that their dismissal was without prejudice.
The detailed version
- Thomas v. The Regents of the University of California · No. 3:19-cv-06463
- Susan Illston
- Sept. 2, 2020
Background
Renee Thomas moved to alter or amend the judgment after the court previously dismissed her state-law claims with prejudice. She asked the court to reconsider that disposition and instead decline supplemental jurisdiction over those claims, allowing her to pursue them in state court. She argued that the state-law claims presented issues separate from her Title IX claims, including the “special relationship” doctrine as it related to her breach-of-fiduciary-duty claim.
The motion was scheduled for a hearing, but the court vacated the hearing and resolved the matter without oral argument under Civil Local Rule 7-11(b).
Ruling
The court stated that it had discretion to grant the motion. After considering Thomas’s arguments, it found that fairness and comity supported amending the prior order and judgment to decline supplemental jurisdiction over the state-law claims. The court granted Thomas’s motion to alter or amend and ordered that an amended judgment be entered. The order clarified that dismissal of the state-law claims was without prejudice.
Effect
The order changed the earlier dismissal of Thomas’s state-law claims from dismissal with prejudice to dismissal without prejudice. The opinion does not decide the merits of those claims or the Title IX claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.