Morris v. Board of Trustees of the California State University
- Haywood Gilliam
- 4:23-cv-04562
- U.S. District Court · Northern District of California
- 7
In Morris v. Board of Trustees, Judge Gilliam denied remand and partly granted the defendants’ dismissal motion, dismissing two federal claims while leaving state claims unresolved.
Matthew Morris and the CSU Defendants; the order dismissed Morris’s sixteenth and twentieth federal causes of action, left the state-law claims unresolved, and allowed one final amendment.
What happened
In Morris v. Board of Trustees of the California State University, Matthew Morris asked the Northern District of California to send his case back to state court. The CSU Defendants asked the court to dismiss the claims against them. The case had originally been removed to federal court after federal defendants invoked the federal-officer removal statute, but those federal defendants were later dismissed.
The court denied Morris’s motion to remand because federal jurisdiction was proper when the case was removed, and the later dismissal of the federal defendants did not eliminate that jurisdiction. The court granted the CSU Defendants’ motion to dismiss Morris’s sixteenth claim, alleging a conspiracy to violate federal criminal law, and his twentieth claim, alleging improper disclosure of medical information under the Health Insurance Portability and Accountability Act. The court dismissed the medical-information claim without leave to amend, but it did not rule on the viability of Morris’s state-law claims at that time.
Judge Haywood S. Gilliam, Jr. granted Morris one final opportunity to amend, within 30 days, without adding parties or causes of action. The court granted in part and denied in part the CSU Defendants’ motion to dismiss, denied the motion to remand, and warned that it would likely remand the case if Morris did not adequately plead a federal claim or chose not to assert one.
The detailed version
- Morris v. Board of Trustees of the California State University · No. 4:23-cv-04562
- Haywood Gilliam
- Apr. 2, 2024
Background
Matthew Morris sued the Board of Trustees of the California State University and other defendants. The case had been removed from state court in March 2023. The federal defendants cited the federal-officer removal statute, 28 U.S.C. § 1442(a)(1). Those federal defendants were later dismissed.
After the court initially dismissed the case for failure to prosecute and entered judgment for the CSU Defendants, Morris moved for relief from judgment. The court granted that motion, reopened the case, and set aside the judgment. It then considered Morris’s motion to remand and the CSU Defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legally recognizable claim.
Motion to Remand
Morris argued that the case should be returned to Department 17 of the Alameda County Superior Court because the federal defendants had been dismissed. The CSU Defendants argued that the federal court still had jurisdiction and should decide their dismissal motion.
The court concluded that removal was proper when it occurred. It explained that later developments generally do not destroy jurisdiction that existed when the case was filed or removed. The court also noted that two of Morris’s claims invoked federal law, giving the court federal-question jurisdiction over those claims. The court therefore DENIED Morris’s motion to remand.
Motion to Dismiss
Morris pleaded 29 causes of action. The court identified two claims that invoked federal law:
- The sixteenth cause of action was labeled “Civil Conspiracy to Violate 18 U.S. Code § 241,” along with a California Penal Code provision. - The twentieth cause of action was labeled “improper disclosure of health/medical information” under the Health Insurance Portability and Accountability Act, along with a California statute.
The court found that the allegations supporting these claims were largely identical to allegations supporting other claims and did not provide enough specific facts. For the conspiracy claim, the complaint did not adequately explain who was involved, how they acted together, or what acts furthered the alleged conspiracy. For the medical-information claim, the complaint did not identify what medical information was disclosed, when it was disclosed, or how it was disclosed. The court also held that the federal health-information law does not provide individuals with a private right to sue for violations of that law.
The court therefore GRANTED the CSU Defendants’ motion to dismiss the sixteenth and twentieth causes of action. It dismissed the twentieth cause of action without leave to amend because amendment would be futile as a matter of law. The order granted Morris one final opportunity to amend the complaint, subject to the limits described below.
State-Law Claims
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over the remaining state-law claims. Supplemental jurisdiction is the court’s discretionary authority to hear related state-law claims after federal claims have been dismissed. The court said this was the usual situation in which the relevant factors favored declining jurisdiction.
The court DENIED the CSU Defendants’ motion to dismiss Morris’s state-law claims without considering their viability at that time. Thus, the order did not decide whether those state-law claims were adequately pleaded.
Disposition and Amendment
The court DENIED Morris’s motion to remand and GRANTED IN PART and DENIED IN PART the CSU Defendants’ motion to dismiss. Morris may file one final amended complaint within 30 days. He may not add new parties or new causes of action, although he may remove defendants or causes of action. The court stated that it would be strongly disinclined to exercise supplemental jurisdiction, and would very likely remand the case to Alameda County Superior Court, if Morris failed to adequately plead a federal claim or chose not to assert one.
Judge Haywood S. Gilliam, Jr. signed the order on April 2, 2024.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.