Executive Software North America, Inc. v. United States District Court for the Central District of California

Brief Fact Summary.

An employment discrimination complaint filed against Petitioners alleged two federal causes of action and three state law causes of action. Petitioners sought a writ of mandamus to compel the district court, which had remanded the state law claims after the action was removed to federal court by Petitioners, to retain jurisdiction over the state law claims.

Synopsis of Rule of Law.

If supplemental jurisdiction is permissible under 28 USC 1367(a) and (b), remand of pendent claims is allowed only for the reasons set forth in 1367(c)(1) – (3), or (4), which allows for remand  under exceptional circumstances, when there are other compelling reasons.

Facts.

Petitioners were sued by Donna Page (referred to in the opinion as the plaintiff-real-party-in-interest) for employment discrimination. Page alleged two federal cause of action and three state law causes of action. Petitioners removed the action to federal court. The district court, sua sponte, issued an order to show cause whey the state law claims should not be remanded to the state court. Without providing reasons, the district court remanded the state law claims. Petitioners sought a writ of mandamus to compel the district court to retain jurisdiction over the state law claims.

Issue.

Did the district court err in remanding the state law claims?

Held.

Yes. The district court erred to the extent that it remanded the state law claims for a reason not permitted under 28 USC 1367(c); because the district court did not provide any reason for its remand, the Court of Appeals could not determine whether the district court relied on a statutory ground and exercised discretion for remand in a permissible manner.

Dissent.

Justice Leavy

A dissent argued that the district court did not err unless it relied on an unauthorized ground to decline supplemental jurisdiction, and that there was no indication that exceeded its authority and did so.

Discussion.

Given the court’s holding — that if supplemental jurisdiction is permissible under 28 USC 1367(a) and (b), remand of pendent claims is allowed only for the reasons set forth in  28 USC 1367(c)(1) – (4) —  the district court clearly erred by not articulating reasons for remand of the pendent claims; the Court of Appeals could not determine whether discretion to remand the claims was properly exercised.