M.P.G. v. Antioch Unified School District

Background

M.P.G., through a guardian ad litem, sued Antioch Unified School District and other defendants. The complaint asserted four types of claims: discrimination under the Americans with Disabilities Act, a violation of Section 504 of the Rehabilitation Act of 1973, negligence, and a violation of California Education Code section 220.

On September 5, 2023, the court dismissed every claim except negligence. Although the court was unsure whether M.P.G. could plausibly plead the dismissed federal and California statutory claims, it gave M.P.G. a final opportunity to amend the complaint by September 26, 2023. M.P.G. did not file an amended complaint. The negligence claim was therefore the only claim still pending.

Jurisdictional issue

Federal courts may hear cases involving federal law or cases meeting the requirements for diversity jurisdiction. Federal-question jurisdiction covers claims arising under the Constitution, federal laws, or treaties. Diversity jurisdiction generally requires more than $75,000 in controversy and citizenship in different states.

M.P.G.’s complaint alleged federal-question jurisdiction, but the court explained that all claims supporting that basis of jurisdiction had been dismissed. The court also determined that diversity jurisdiction did not exist because the complaint described M.P.G. as a resident of Antioch in Contra Costa County, California, and described Antioch Unified School District as a public entity incorporated and operating under California law.

The court then considered supplemental jurisdiction, which can allow a federal court to hear related state-law claims when the court has original jurisdiction over a federal claim. Under 28 U.S.C. § 1367(c)(3), a court may decline supplemental jurisdiction after dismissing all claims over which it had original jurisdiction. The court stated that, because the case was still at the pleading stage, judicial economy favored declining supplemental jurisdiction over M.P.G.’s negligence claim.

Order

The court did not immediately dismiss the case. Instead, it ordered M.P.G. to show cause—meaning to explain—why the case should not be dismissed for lack of subject-matter jurisdiction. M.P.G. was ordered to file a written response by October 4, 2023. The court stated that failure to respond would result in dismissal of the action for lack of subject-matter jurisdiction. The court also stated that the negligence claim would be dismissed without prejudice to refiling in state court if the court declined supplemental jurisdiction.