Michael Carter, DMD v. Life Dental Group, LLC; LD-Ridgeland, LLC; Jeff Hand; William Alias; and Mike Huggins

CourtDistrict Court, N.D. Mississippi
DecidedApril 13, 2026
Docket3:24-cv-00183
StatusUnknown

This text of Michael Carter, DMD v. Life Dental Group, LLC; LD-Ridgeland, LLC; Jeff Hand; William Alias; and Mike Huggins (Michael Carter, DMD v. Life Dental Group, LLC; LD-Ridgeland, LLC; Jeff Hand; William Alias; and Mike Huggins) is published on Counsel Stack Legal Research, covering District Court, N.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Carter, DMD v. Life Dental Group, LLC; LD-Ridgeland, LLC; Jeff Hand; William Alias; and Mike Huggins, (N.D. Miss. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI OXFORD DIVISION

MICHAEL CARTER, DMD PLAINTIFF

v. CIVIL ACTION NO. 3:24-CV-183-MPM-RP

LIFE DENTAL GROUP, LLC, LD-RIDGELAND, LLC; JEFF HAND; WILLIAM ALIAS; AND MIKE HUGGINS DEFENDANTS

ORDER This cause comes before the court on plaintiff Michael Carter’s motion to amend the case management order (CMO) in this case in order to permit him to file an amended complaint. Defendants have responded in opposition to the motion, and the court, having considered the memoranda and submissions of the parties, is prepared to rule. This case involves various state and federal claims arising out of plaintiff’s agreement to sell his Ridgeland dental practice to defendants. Aside from a breach of contract claim, plaintiff alleges that defendants committed various acts of misconduct which, he contends, amounted to a breach of the duty of good faith and fair dealing and malicious interference with prospective employment under Mississippi law. While defendants have filed a summary judgment motion as to these state law claims, this court must first consider jurisdictional issues arising from plaintiff’s sole federal claim, which he now seeks to withdraw, that defendants violated the provisions of the Sherman Act, set forth in 15 USC §§ 1 to 7. The Sherman Act is, of course, a federal antitrust statute prohibiting unreasonable restraints of trade, and it was plaintiff’s initial assertion of a violation of this Act which gave rise to federal jurisdiction in this case. Prior to addressing plaintiff’s motion to withdraw his Sherman Act claim, this court will note the factual context in which it arose. In describing the facts which gave rise to this case, plaintiff alleges in his complaint that: The Defendant LLCs are in the business of buying and operating dental practices. The individual Defendants control the Defendant LLCs, and developed their business model, which is to purchase successful dental practices and then to employ the former owners of the business. Prior to Plaintiff’s selling his dental business to his daughter, the Defendant LLCs, acting through the individual Defendants, had attempted, without success, to buy Plaintiff’s dental business. After Plaintiff sold his dental business to his daughter, Defendants resumed their efforts to purchase the business. Defendants ultimately succeeded in persuading Plaintiff’s daughter to sell them the assets of the business in Ridgeland, Mississippi. Defendants, however, needed Plaintiff to remain employed at the business because Plaintiff had developed an excellent reputation as a dentist, and having Plaintiff leave the business would be financially harmful to Defendants. In order to induce Plaintiff’s daughter to agree to the sale of the business and in order to induce Plaintiff to become an employee of the business, Defendants, acting through Defendant Alias, promised Plaintiff that if he would agree to become an employee of the business, Defendants would retain the name of the business, allow Plaintiff to select and supervise the staff of the business, allow Plaintiff to determine who would be employed in the business, and allow Plaintiff to continue to choose the vendors with whom the business worked. Because of the above promises, Plaintiff agreed to enter an employment contract with Defendant LD-Ridgeland, which was owned and controlled by the other Defendants. Soon after Plaintiff became an employee of Defendant LD-Ridgeland, LLC, under the Employment Agreement, Plaintiff learned that Defendants would not keep the promises they had made to induce him to become an employee of the business. Contrary to what Defendants had told Plaintiff to induce him to become an employee, Defendants changed the name of the business, selected the employees of the business, and placed budgetary restrictions on amounts the clinic could spend which were so substantial as to harm patient care. Much more significant than the fact that Defendants breached the promises they made to induce him to become an employee, Defendants also adopted practices which would require Plaintiff to engage in unethical and illegal practices.

[Complaint at 4-5]. In the interest of brevity, this court will omit the alleged “unethical and illegal practices” which plaintiff contends that defendants sought for him to engage in, but it will note the allegations which support the Sherman Act claim which is central to the present motion. In this vein, plaintiff alleged in his original complaint that defendants required him to sign a non- compete agreement which, he alleges, amounted to an unlawful restraint of trade and a violation of the Sherman Act, as follows: The Sherman Act, 15 U.S.C. § 1, prohibits enforcement of contracts which are “in restraint of trade or commerce among the several States. . . .” This prohibition on restraints of trade prohibits all “undue” restraints of trade and disallows “unreasonable” restraints on trade. The noncompete agreement is a per se violation of the Sherman Act. Alternatively, the non-compete fails the “rule of reason” analysis. It prohibits Plaintiff from engaging in his chosen profession of dentistry, within ten (10) miles of the area where Plaintiff worked, and unreasonably keeps Plaintiff from having his own patients and, in effect, prohibits patients from choosing their dentist. The agreement restrains interstate commerce, since many of Plaintiff’s patients are out-of-state patients, and would otherwise travel to utilize Plaintiff's services as a dentist. Furthermore, the supplies used in the dental practice and purchased by the business are manufactured in substantial part by out-of-state manufacturers. The employment agreement, Exhibit “A,” is also an unreasonable restraint of trade because it arbitrarily gives Plaintiff’s patients to corporate entities. It denies Plaintiff’s patients choices as to who their dentist will be. By denying consumers choices among dentists, the employment agreement unreasonably restrains trade among the several states, it artificially affects the ability of patients to travel across state lines to a dentist of the choice, and causes patients not to travel to central Mississippi from other states to obtain Plaintiff’s services.

[Complaint at 7]. With these allegations in mind, this court now turns to plaintiff’s request to file an amended complaint which 1) omits his Sherman Act claim and 2) alleges additional facts in support of his breach of contract claim. In doing so, this court emphasizes at the outset that the parties are in agreement that, if it grants plaintiff’s request to file an amended complaint asserting purely state-law claims, then it must thereupon dismiss this case for lack of subject matter jurisdiction. Indeed, defendants concede in their brief that: As Plaintiff has argued, the Supreme Court has recently held that when the Plaintiff amends the complaint and removes all federal claims, the district court must dismiss the state law claims without prejudice because it no longer maintains supplemental jurisdiction under 28 U.S.C. 1367. See Royal Canin USA Inc. v. Wullschleyer, 145 S. Ct. 41 (2025). If Plaintiff’s motion is granted, dismissal is certain under the Royal Canin opinion. [Brief at 4]. The Supreme Court’s decision in Royal Canin was consistent with its earlier decision in Rockwell Int'l Corp. v. United States, 549 U.S. 457, 473–474, 127 S.Ct. 1397 (2007) where it held that “when a plaintiff files a complaint in federal court and then voluntarily amends the complaint, courts look to the amended complaint to determine jurisdiction.” While the U.S.

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Michael Carter, DMD v. Life Dental Group, LLC; LD-Ridgeland, LLC; Jeff Hand; William Alias; and Mike Huggins, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-carter-dmd-v-life-dental-group-llc-ld-ridgeland-llc-jeff-msnd-2026.