Silver v. Greystar Real Estate Partners, LLC

Background

Aimee Silver brought claims under the Fair Housing Act, a federal housing-discrimination statute, and several state laws. The court had federal-question jurisdiction over the Fair Housing Act claim and supplemental jurisdiction, meaning authority to hear related state-law claims, under 28 U.S.C. §§ 1331 and 1367.

Motion to Amend and Jurisdiction

Silver moved for leave to amend her First Amended Complaint. The proposed amendment would withdraw her only federal claim, leaving only state-law claims. The defendants opposed the motion, arguing that Silver was trying to destroy federal jurisdiction by changing her claims. The court granted leave to amend and requested briefing on whether it should retain supplemental jurisdiction over the remaining state-law claims.

Silver argued that the court should not retain jurisdiction. The defendants filed a notice stating that they did not oppose Silver’s position.

Court’s Analysis

The court stated that when all federal claims are dismissed before trial, district courts generally should decline to exercise supplemental jurisdiction over related state-law claims. In deciding whether to retain jurisdiction, courts consider judicial economy, convenience, fairness, and comity. Although the case had been delayed by discovery disputes and an attorney’s withdrawal, the court noted that no substantive motions had been decided. Given the early stage of the litigation and the parties’ agreement that the state-law claims should be dismissed, the court found no reason to retain supplemental jurisdiction.

Disposition

Judge Susan Illston ordered that Silver’s complaint be dismissed without prejudice. The opinion does not decide the merits of the Fair Housing Act or state-law claims.