Morris v. Board of Trustees of the California State University
- Haywood Gilliam
- 4:23-cv-04562
- U.S. District Court · Northern District of California
- 2
In Morris v. Board of Trustees, Judge Gilliam remanded the remaining state-law claims to California state court after dismissing all claims within federal jurisdiction.
Matthew Morris and the defendants are affected: the remaining California state-law claims will proceed in the Superior Court of California, County of Alameda, rather than in federal court, and the federal court file will be closed.
What happened
In Morris v. Board of Trustees of the California State University, the second amended complaint asserted state-law claims against state defendants. The federal claims over which the court had original jurisdiction had already been dismissed.
The defendants argued that the federal court should keep the remaining claims under supplemental jurisdiction, which can allow a federal court to hear related state-law claims. The court declined to do so because no claims within its original jurisdiction remained.
Judge Haywood S. Gilliam, Jr. remanded the case to the Superior Court of California, County of Alameda, and directed the Clerk to close the federal file. The opinion states that the defendants had not yet moved to dismiss the second amended complaint and therefore would not be prejudiced by responding in state court.
The detailed version
- Morris v. Board of Trustees of the California State University · No. 4:23-cv-04562
- Haywood Gilliam
- May 28, 2024
Background
Matthew Morris’s second amended complaint brought state-law claims against state defendants. The court had previously dismissed all claims over which it had original jurisdiction. The opinion does not identify those dismissed claims.
Jurisdictional ruling
The defendants argued that the court should exercise supplemental jurisdiction over the remaining state-law claims. Supplemental jurisdiction is a federal court’s authority to hear related state-law claims after federal claims are also part of the case. Under 28 U.S.C. § 1367(c)(3), a court may decline that jurisdiction when it has dismissed all claims over which it had original jurisdiction.
The court declined to exercise supplemental jurisdiction. It stated that the usual course in this situation is to have the remaining California state-law claims resolved by a California state court. The court also noted that the defendants had not yet filed a motion to dismiss the second amended complaint, so they would not be prejudiced by presenting their response as a state-court demurrer.
Disposition
Judge Haywood S. Gilliam, Jr. remanded the case to the Superior Court of California, County of Alameda, and directed the Clerk to close the federal file. The order did not state that the remand or any dismissal was with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.