H. v. Montessori School at Washington Avenue, Inc.

Background

M. H., a young child proceeding through his mother and guardian ad litem, Lisbeth Zamora, sued Montessori School at Washington Avenue, Inc. and its director, Pamela Zell Rigg. The complaint alleged violations of the Americans with Disabilities Act, California's Unruh Civil Rights Act, negligent infliction of emotional distress, and intentional infliction of emotional distress. The defendants removed the case from the Superior Court of California for Alameda County to federal court based on federal-question jurisdiction arising from the Americans with Disabilities Act claim.

Motions

M. H. sought permission under Federal Rule of Civil Procedure 15 to amend the complaint. The proposed amendment would add Zamora as a plaintiff, add claims for breach of contract and breach of the implied covenant of good faith and fair dealing, and delete the Americans with Disabilities Act claim. After that claim was removed, only state-law claims would remain. M. H. therefore also asked the court to remand, meaning send, the case back to state court.

Court's analysis

The court found no undue delay, bad faith, prejudice, or futility that would justify denying permission to amend. The defendants did not oppose adding Zamora and her claims, and their main objection was that the amendment would allow the case to return to state court. The court concluded that this did not constitute legally cognizable prejudice and that M. H. could choose to proceed only under state law.

The court then declined to exercise supplemental jurisdiction over the remaining state-law claims. Supplemental jurisdiction is a federal court's discretionary authority to hear state-law claims related to claims within its original jurisdiction. The court emphasized that the federal claim had been removed before trial and before any substantive judicial rulings. It rejected the defendants' arguments that the Unruh Act claim depended on the Americans with Disabilities Act claim or that references to an individual education plan necessarily created a remaining federal claim.

Disposition

The court granted the motion for leave to file an amended complaint. It deemed the proposed amended complaint filed and operative, declined supplemental jurisdiction over the remaining state-law claims, and granted the motion to remand. The case was remanded to the Superior Court of California for the County of Alameda. The court did not decide the merits of the disability, emotional-distress, contract, or other state-law claims.