Newbary v. Enterprise RAC Company of Montana/Wyoming, LLC

CourtDistrict Court, D. Montana
DecidedJanuary 20, 2022
Docket9:21-cv-00093
StatusUnknown

This text of Newbary v. Enterprise RAC Company of Montana/Wyoming, LLC (Newbary v. Enterprise RAC Company of Montana/Wyoming, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Newbary v. Enterprise RAC Company of Montana/Wyoming, LLC, (D. Mont. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION

KARIS NEWBARY and BRANDIE CV 21–93–M–DLC HOY,

Plaintiffs, ORDER vs.

ENTERPRISE RAC COMPANY OF MONTANA/WYOMING, LLC; DEVIN HUTTON; JORDAN COBB; and DOE DEFENDANTS 1-3,

Defendants.

Before the Court is Plaintiffs Karis Newbary and Brandie Hoy’s Motion to Remand. (Doc. 6.) The Court will grant the motion. Defendants removed this action to federal court on August 19, 2021. (Doc. 1.) Plaintiffs’ operative state court complaint (the “FAC”) at the time of removal alleged wrongful discharge under the Montana Wrongful Discharge from Employment Act (“WDFEA”), Mont. Code Ann. § 39-2-901; disability discrimination under the Montana Human Rights Act (“MHRA”), Mont. Code Ann. § 49-2-303, and Americans with Disabilities Act, 42 U.S.C. § 12101; age discrimination under the MHRA and the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621; and sex discrimination under the MHRA and Title VII of the Civil Rights Act, 42 U.S.C. §2000e. (Doc. 4.) The FAC expressly alleged that Defendants violated federal law and sought relief under federal

statutes. (Id. ¶¶ 42, 47, 51; id. at 17.) On August 25, 2021, Plaintiffs filed their Second Amended Complaint (“SAC”). (Doc. 5.) Although the SAC continues to refer to the ADA, ADEA, and

Title VII as relevant to the interpretation of Montana statutes (id. ¶¶ 38, 42, 44–45, 49), the SAC removed any claim for relief under any federal statute (id. ¶¶ 42, 47, 51; id. at 17–18). Plaintiffs filed a motion to remand on August 31, arguing that “Plaintiffs’ SAC clarifies that the asserted claims are based solely upon

Defendants’ violation of state law” and “[a]ll arguably federal claims that may have existed in the FAC have been removed.” (Doc. 6-1 at 5.) Defendants respond that federal question jurisdiction existed at the time of

removal, and because removal was proper based on the then-operative complaint, remand should be denied. (Doc. 9 at 2.) Defendants further argue that the SAC continues to assert violations of federal discrimination laws, and the Court should exercise supplemental jurisdiction over Plaintiffs’ state-law claims. (Id.)

Congress enacted 28 U.S.C. § 1331 to provide federal district courts with “original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” A case arises under federal law “when federal law

creates the cause of action asserted.” Gunn v. Minton, 568 U.S. 251, 257 (2013). The well-pleaded complaint rule “provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff’s properly pleaded

complaint.” Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987). Critically here, in assessing whether federal question jurisdiction exists, the Court must “consider only ‘the pleadings filed at the time of removal without reference to

subsequent amendments.’” City of Oakland v. BP PLC, 969 F.3d 895, 903 (9th Cir. 2020) (quoting Provincial Gov’t of Marinduque v. Placer Dome, Inc., 582 F.3d 1083, 1085 n.1 (9th Cir. 2009)). Plaintiffs’ FAC plainly asserted claims arising under federal law because

Plaintiffs alleged violations of, and sought relief under, several federal statutes: the ADA, the ADEA, and Title VII of the Civil Rights Act. (Doc. 4 at 13–17.) Indeed, Title VII itself confers federal jurisdiction over claims brought under that

law, independent of 28 U.S.C. § 1331. Arbaugh v. Y&H Corp., 546 U.S. 500, 505–06 (2006). Plaintiffs’ mendacious attempt to characterize the FAC’s federal claims as mere “reference[s]” to federal law (Doc. 6-1 at 8) is easily rejected. Accordingly, federal question jurisdiction existed over those claims at the time of

removal. Once federal question jurisdiction is established over some claims in an action, the Court has discretion to exercise jurisdiction over the entire action

“whenever the federal-law claims and state-law claims in the case ‘derive from a common nucleus of operative fact’ and are ‘such that [a plaintiff] would ordinarily be expected to try them all in one judicial proceeding.” Carnegie-Mellon Univ. v.

Cohill, 484 U.S. 343, 349 (1988) (quoting Mine Workers v. Gibbs, 383 U.S. 715, 725 (1966)); see also 28 U.S.C. § 1367(a). Plaintiffs’ state-law disability, age, and sex discrimination claims in the FAC easily satisfy this test because they were

alleged alongside their federal counterparts and rest on the same factual allegations underlying their federal claims. (Doc. 4 at 13–16.) Plaintiffs’ WDFEA claims likewise satisfy this test because they arise from the same common nucleus of operative fact—i.e., Defendants’ termination of Plaintiffs’ employment—alleged

in the FAC as their federal claims. (Id. at 3–10.) The values of judicial economy, convenience, and fairness to the litigants support the exercise of pendent jurisdiction over these claims because refusing to exercise jurisdiction over these

claims would force the parties to litigate the facts surrounding Plaintiffs’ terminations, and by extension their legality, in two courts simultaneously. See Carnegie-Mellon Univ., 484 U.S. at 349. Accordingly, this Court had federal question and pendent jurisdiction over the entirety of the action when it was

removed, and removal was proper. However, the picture has changed upon Plaintiffs’ amendment of their complaint to remove any request for relief under federal law. Defendants assert

that Plaintiffs continue to raise claims arising under federal law (Doc. 9 at 9–10), but the Court disagrees. The SAC’s citations to federal law concern the interpretation of corresponding state anti-discrimination laws, and Plaintiffs seek

relief only under state statutes; accordingly, the SAC does not “necessarily raise[]” a federal issue as required for the exercise of federal question jurisdiction over state law claims. Gunn, 568 U.S. at 258; Rains v. Criterion Sys., Inc., 80 F.3d 339,

343–44 (9th Cir. 1996) (holding that reference to Title VII did not render claim federal where state law created the cause of action). “That the same facts could have been the basis for a Title VII claim does not make [Plaintiffs’] wrongful termination claim into a federal cause of action.” Rains, 80 F.3d at 344.

Plaintiffs’ decision to effectively voluntarily dismiss their federal claims by filing an amended complaint removing those claims does not necessitate remand. The Court instead has “discretion to remand when the exercise of pendent

jurisdiction is appropriate.” Carnegie-Mellon Univ., 484 U.S. at 351.

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Related

United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Gunn v. Minton
133 S. Ct. 1059 (Supreme Court, 2013)
Provincial Gov't of Marinduque v. Placer Dome, Inc.
582 F.3d 1083 (Ninth Circuit, 2009)
Millar v. Bay Area Rapid Transit District
236 F. Supp. 2d 1110 (N.D. California, 2002)
City of Oakland v. Bp P.L.C.
969 F.3d 895 (Ninth Circuit, 2020)
Rains v. Criterion Systems, Inc.
80 F.3d 339 (Ninth Circuit, 1996)

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Newbary v. Enterprise RAC Company of Montana/Wyoming, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newbary-v-enterprise-rac-company-of-montanawyoming-llc-mtd-2022.