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Executive Software North America, Inc. v. United States District Court for the Central District of California | 24 F.3d 1545 (1994)

Supplemental jurisdiction may arise if a case involves multiple claims. In this situation, some claims are within the federal court’s subject-matter jurisdiction while others, such as state-law claims, have no independent jurisdictional basis. If the court has jurisdiction over one claim, it may be able to entertain related claims as part of its supplemental jurisdiction. As a practical matter, supplemental jurisdiction sidesteps the need to split claims between the federal and state systems.

But can federal courts choose whether to tackle the supplemental claims? In Executive Software North America versus United States District Court, the federal court seemingly was busy and didn’t want to hear the supplemental claims.

Donna Page claimed that her employer, Executive Software North America, fired her for discriminatory reasons. Page sued for two federal causes of action and three state-law causes of action in a California court.

Based on the federal claims, Executive Software removed the case to federal court. The district court issued an order directing the parties to show cause why the state-law claims shouldn’t be remanded to state court. The show-cause order warned that the court relied on a Supreme Court precedent, United Mine Workers versus Gibbs, rather than the supplemental jurisdiction statute in determining whether to remand claims without an independent jurisdictional basis.

Now to some background. Gibbs authorized federal courts to decline jurisdiction if doing so would accommodate, quote, “the values of economy, convenience, fairness, and comity,” unquote. Comity, by the way, refers to a proper respect for state courts. Thus, arguably, under Gibbs, courts had significant discretion. A multitude of circumstances could warrant declining jurisdiction.

After Gibbs, Congress enacted a supplemental jurisdiction statute, Title Twenty-Eight of the United States Code, Section Thirteen Sixty-Seven. Subsection (c) grants a district court discretion to decline jurisdiction over supplemental claims in four situations. One, if the claim raises a novel or complex issue of state law. Two, if the supplemental claim predominates over the federal claims. Three, if the federal claims have been dismissed. Four, if in exceptional circumstances, there are other compelling reasons to decline jurisdiction.

After considering the parties’ arguments, the court remanded the state claims to state court without articulating a rationale. The court hinted that the state-law claims would take time and effort.

Remand orders aren’t typically appealable. Executive Software, facing the need to defend claims in both state and federal courts, sought a writ of mandamus in the Ninth Circuit. The writ would compel the district court to exercise jurisdiction over the state law claims.

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