Marida Silas v. Sheriff of Broward County, Florida

55 F.4th 863
Court of Appeals for the Eleventh Circuit·Decided December 14, 2022·No. 21-14200·Published·Cited by 34 cases

Opinion

USCA11 Case: 21-14200 Document: 39-1 Date Filed: 12/14/2022 Page: 1 of 8

[PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

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No. 21-14200 ____________________

MARIDA SILAS, individually, and in her prospective capacity as Personal Repre- sentative of the Estate of Rochenel Silas, Plaintiff - Appellant, versus SHERIFF OF BROWARD COUNTY, FLORIDA, Defendant - Appellee

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Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 0:20-cv-61480-WPD ____________________ USCA11 Case: 21-14200 Document: 39-1 Date Filed: 12/14/2022 Page: 2 of 8

2 Opinion of the Court 21-14200

Before WILLIAM PRYOR, Chief Judge, ROSENBAUM, and MARCUS, Circuit Judges. WILLIAM PRYOR, Chief Judge: This appeal concerns whether the district court abused its discretion when it declined to exercise supplemental jurisdiction over a plaintiff’s state-law claims after it dismissed her federal claims. Federal law grants district courts the discretion to decline to exercise supplemental jurisdiction. And this Court has encour- aged district courts to remand pendent state-law claims to state courts after the federal claims are dismissed. Because the district court followed our guidance and acted within its broad discretion when it remanded this case to state court, we affirm. I. BACKGROUND Marida Silas brought federal and state claims on behalf of her late husband against the Sheriff of Broward County, Florida after her husband’s 2011 arrest. The Sheriff removed the case to federal district court based on the presence of the federal claims. But the district court later dismissed the federal claims. See Case No. 21- 13946. The district court initially continued to exercise supple- mental jurisdiction over the pendent state claims and set the matter for trial on November 5, 2021. But on November 3, the Sheriff moved to dismiss Silas’s state claims because Silas had not been ap- pointed as the personal representative of her husband’s estate. USCA11 Case: 21-14200 Document: 39-1 Date Filed: 12/14/2022 Page: 3 of 8

21-14200 Opinion of the Court 3

The district court cancelled the trial and reset it for Novem- ber 9. The district court ordered Silas to file an expedited response to the motion to dismiss. Silas did so and argued that she could pursue her husband’s claims because her actions would relate back after she received a valid appointment as representative of her hus- band’s estate from the probate court. She asked the district court either to allow trial to proceed or to “abate this action for a reason- able time until the . . . probate court appoint[ed] a personal repre- sentative.” The Sheriff replied that the district court should dismiss the action because Silas had failed to secure her appointment as representative of the estate before the scheduled trial. After the parties submitted these filings, the district court did not rule on the motion to dismiss. Instead, on November 5, it or- dered the parties to address “whether the [c]ourt now has only sup- plemental jurisdiction over the remaining claims in this case and, if so, whether the case should be remanded to state court.” The Sher- iff responded and argued that the district court should continue to exercise jurisdiction because the trial was set to commence in four days and substantial discovery had already occurred. Silas joined the Sheriff’s request. On November 8, the district court declined supplemental ju- risdiction and remanded the case to state court. The district court stated that it “would not normally decline supplemental jurisdic- tion over a case on the eve of trial based upon the dismissal of all federal question claims.” But the district court found that it could not move forward with trial because Silas had “not acted with USCA11 Case: 21-14200 Document: 39-1 Date Filed: 12/14/2022 Page: 4 of 8

4 Opinion of the Court 21-14200

diligence in pursuing the appointment of personal representative of [her husband’s] estate” and “lack[ed] standing to prosecute th[e] case at this juncture.” Because trial could not proceed, the district court had to decide whether dismissal or a stay was appropriate. It concluded that it “would likely have abated and not dismissed the case,” so “the trial would have been postponed.” But due to a “backlog of criminal trials,” it found that “there [wa]s no certainty that this court would have been able to try th[e] case in the near future.” So, the district court declined to exercise supplemental ju- risdiction and remanded the case to state court. II. STANDARD OF REVIEW We review a decision to decline supplemental jurisdiction over a state-law claim for abuse of discretion. Shotz v. City of Plan- tation, 344 F.3d 1161, 1185 (11th Cir. 2003). III. DISCUSSION Consistent with our deference to state courts on issues of state law, federal courts may exercise supplemental jurisdiction over state-law claims in limited circumstances. One such circum- stance is when the state claims “arise out of a common nucleus of operative fact with a substantial federal claim.” Parker v. Scrap Metal Processors, Inc., 468 F.3d 733, 743 (11th Cir. 2006); see also 28 U.S.C. § 1367(a). In this case, the parties agree that the state claims arose out of a common nucleus of operative fact with the federal claims. So, the district court had the authority to exercise supplemental jurisdiction over Silas’s state claims. USCA11 Case: 21-14200 Document: 39-1 Date Filed: 12/14/2022 Page: 5 of 8

21-14200 Opinion of the Court 5

After it dismissed the federal claims, the district court had the discretion either to continue to exercise supplemental jurisdic- tion over the state claims or to dismiss them. See Baggett v. First Nat’l. Bank of Gainesville, 117 F.3d 1342, 1352 (11th Cir. 1997); CHARLES ALAN WRIGHT, ARTHUR R. MILLER & EDWARD H. COOPER, FEDERAL PRACTICE AND PROCEDURE § 3567.3 (3d ed. 2022). That discretion is “expressly conferred to district courts by statute.” Mergens v. Dreyfoos, 166 F.3d 1114, 1119 (11th Cir. 1999) (citing 28 U.S.C. § 1367(c)). And it “continues throughout the pro- ceeding.” L.A. Draper & Son v. Wheelabrator-Frye, Inc., 735 F.2d 414, 427 (11th Cir. 1984). The district court’s discretion is broad. We have observed that “the doctrine of pendent jurisdiction . . . is a doctrine of flexibility, designed to allow courts to deal with cases involving pendent claims in the manner that most sensibly accom- modates a range of concerns and values.” Ameritox, Ltd. v. Millen- nium Lab’ys., Inc., 803 F.3d 518, 530 (11th Cir. 2015) (citation omit- ted). And we have explained that “considerations of judicial econ- omy, convenience, fairness, and comity may influence the court’s discretion.” Baggett, 117 F.3d at 1353. Although the district court has discretion, concerns of feder- alism—namely, of federal courts of limited jurisdiction weighing in on state law—counsel in favor of dismissing state-law claims after the federal claims are dismissed. “We have encouraged district courts to dismiss any remaining state claims when, as here, the fed- eral claims have been dismissed prior to trial.” Raney v. Allstate Ins.

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Marida Silas v. Sheriff of Broward County, Florida, 55 F.4th 863 (11th Cir. 2022).

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