Jaiyeola v. Rivian

Background

Ganiyu Ayinla Jaiyeola applied for a materials engineering position with Rivian on April 27, 2020. He alleged that Rivian did not hire him because he is Black, African American, and of Nigerian national origin. He filed charges with the Michigan Department of Civil Rights and the Equal Employment Opportunity Commission. After the Equal Employment Opportunity Commission issued him a notice of the right to sue, Jaiyeola filed this action under Title VII of the Civil Rights Act of 1964 and Michigan’s Elliot-Larsen Civil Rights Act.

The court had previously dismissed Jaiyeola’s complaint because he had not established proper venue for his Title VII claim and had not plausibly alleged an Elliot-Larsen claim. After Jaiyeola filed an amended complaint, Rivian again moved to dismiss both claims.

Title VII and Venue

Rivian moved under Federal Rule of Civil Procedure 12(b)(3), which allows dismissal for improper venue. Jaiyeola did not dispute that he had not corrected the earlier venue deficiencies and did not identify new evidence showing that venue was proper in the Northern District of California.

The court therefore granted Rivian’s motion to dismiss the Title VII claim for improper venue. It dismissed that claim without prejudice to refiling in a district where venue is proper under 42 U.S.C. § 2000e-5(f)(3), but with prejudice to refiling the claim in the Northern District of California.

Elliot-Larsen Claim and Jurisdiction

Rivian argued that the court lacked diversity jurisdiction over the Elliot-Larsen claim. Diversity jurisdiction generally requires all plaintiffs to be citizens of different states from all defendants and requires more than $75,000 to be in dispute. The court stated that Rivian was a citizen of California when Jaiyeola filed the action, and it focused on whether Jaiyeola was also a California citizen at that time.

Jaiyeola’s original complaint stated that he resided in Cupertino, California. The court treated those statements as judicial admissions and as initial evidence that he was domiciled in California when he filed the action. Jaiyeola submitted a declaration and a Michigan driver’s license to support his position that he was domiciled in Michigan. The court found that this evidence did not overcome the initial evidence of California domicile because the declaration addressed the date he filed the amended complaint, rather than the date he filed the original complaint, and the license did not establish his residence on the filing date.

The court held that Jaiyeola had not met his burden of establishing diversity jurisdiction. Because the Title VII claim was dismissed and diversity jurisdiction was unavailable, supplemental jurisdiction was the only possible basis for hearing the Elliot-Larsen claim. Supplemental jurisdiction allows a federal court to hear related state-law claims in some circumstances. The court declined to exercise it because the case was still in its early stages and the related claims could be litigated together in a proper court.

Disposition

Judge Beth Labson Freeman granted Rivian’s motion to dismiss the Title VII claim for improper venue. The claim was dismissed without prejudice to filing in a district where venue is proper under 42 U.S.C. § 2000e-5(f)(3), but with prejudice to refiling in the Northern District of California. The court also granted Rivian’s motion to dismiss the Elliot-Larsen claim for lack of subject matter jurisdiction, without prejudice to filing in the proper court.