Uddin v. Rock Arch & Eng Corp.

Background

Nabila Uddin filed this action in federal court on December 20, 2021, and later filed an amended complaint. The defendants filed a joint motion to dismiss and a motion for remand. The court converted the motion to dismiss into a motion for partial summary judgment and ordered limited discovery concerning federal jurisdiction under Title VII, the federal employment-discrimination statute.

The parties then asked to file a stipulation resolving the pending motion. Their stipulation agreed to dismiss Uddin’s federal causes of action and asked the court to remand her remaining claims under New York State and New York City law to New York State Supreme Court, County of Queens. The court initially approved the stipulation, stated that the Title VII claims were dismissed with prejudice, and remanded the state-law claims.

Court’s ruling

The court reconsidered the remand and held that it lacked authority to send the case to state court because Uddin had originally filed it in federal court rather than in state court and then had the case removed. The court therefore vacated the earlier orders at docket numbers 33 and 34 as to the remand decision only.

The court reaffirmed that the parties’ stipulation was approved. It dismissed Uddin’s Title VII claims with prejudice and ordered all parties to bear their own attorney’s fees and costs connected with those dismissed claims. Because no federal claims remained, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims in the same case—and dismissed the remaining state-law claims without prejudice to refiling them in state court.

Judge Katherine Polk Failla directed the Clerk of Court to terminate all pending motions, adjourn all remaining dates, and close the case.