Karunakaran v. BMCC/Cuny City University of New York
- Edgardo Ramos
- 1:18-cv-10723
- U.S. District Court · Southern District of New York
- 2
In Karunakaran v. Borough of Manhattan Community College, Judge Ramos denied guidance on remand and supplemental jurisdiction because an appeal left the court without jurisdiction.
Chitra Karunakaran, whose motion for guidance was denied; the order also directed the Clerk of Court to terminate that motion.
What happened
In Karunakaran v. Borough of Manhattan Community College, the court had previously dismissed Chitra Karunakaran’s Second Amended Complaint. Karunakaran appealed and later asked to pursue her state-law claims in state court.
Karunakaran then asked the court for guidance about the judge’s procedures concerning remand and decisions not to exercise supplemental jurisdiction over claims under the 2005 New York City Human Rights Law.
Judge Ramos denied the motion. He said the pending appeal left the court without jurisdiction over Karunakaran’s motions, and that remand and supplemental jurisdiction are legal issues rather than matters governed by the judge’s individual procedures.
The detailed version
- Karunakaran v. BMCC/Cuny City University of New York · No. 1:18-cv-10723
- Edgardo Ramos
- June 23, 2023
Background
The court had dismissed pro se plaintiff Chitra Karunakaran’s Second Amended Complaint on March 28, 2022. Karunakaran filed a notice of appeal on April 25, 2022. She later filed motions concerning her ability to pursue state-law claims in state court. The court previously explained that the appeal deprived the district court of jurisdiction over those motions. It also explained that the case had originally been filed in federal court, rather than removed from state court, so there was no case to send back to state court. The March 28, 2022 order had dismissed Karunakaran’s state-law claims without prejudice, meaning the opinion said she was already free to pursue those claims in state court.
Motion
Karunakaran moved for specific guidance about the judge’s Individual Practices. She said she could not find a reference to “Remand” or an explanation of factors concerning decisions not to exercise supplemental jurisdiction based on the 2005 New York City Human Rights Law.
Ruling
Judge Ramos denied the motion. First, he held that the court continued to lack jurisdiction over Karunakaran’s motions because her appeal remained pending. Second, he stated that the legal bases for remand and for exercising supplemental jurisdiction were legal issues, not matters suitable for individual judge’s procedural rules. The court directed the Clerk of Court to terminate the motion, Doc. 87.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.