Allstate Interiors & Exteriors, Inc. v. Stonestreet Construction, LLC, 730 F.3d 67

Allstate Interiors & Exteriors, Stonestreet Construction, Weybosset Hotel are Rhode Island entities involved in a Hampton Inn renovation dispute.
Stonestreet served as construction manager and sued Weybosset; Allstate asserted subcontractor claims and settlement discussions occurred.
GMP fixed at $11,250,000 with CORs for changes; Stonestreet submitted CORs seeking additional funding for delays.
Permanent power delays hindered progress; Weybosset controlled primary service, affecting critical path and schedule.
A ten-day bench trial awarded Stonestreet $571,595; Weybosset appealed on jurisdiction, contract interpretation, and discovery rulings.
Partial settlement between Allstate and Stonestreet left Stonestreet’s counterclaim against Allstate pending, raising supplemental jurisdiction questions over Weybosset-Stonestreet claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court properly exercised supplemental jurisdiction.	Stonestreet/Allstate argue jurisdiction remained proper under 28 U.S.C. §1367(a) and §1367(b) despite non-diverse parties remaining.	Weybosset contends §1367(b) strips jurisdiction when the only remaining claims are non-diverse; also asserts possible §1367(c) decline.	No abuse of discretion; §1367(b) does not strip jurisdiction when original plaintiff is the party invoking it, and §1367(c) discretion preserved jurisdiction.
Whether the contract interpretation and damages calculation were correct under Rhode Island law.	Stonestreet asserts the lump-sum general conditions and COR-based adjustments properly modify §6.2.1 and compensate for delays.	Weybosset contends certain line items were improperly included or waived; argues lack of formal written modification.	District court properly included the lump-sum general conditions and related costs; no reversible error in interpreting the modification/waiver under RI law.
Whether the district court properly denied Weybosset's discovery motion regarding supplemental expert reports.	Stonestreet maintained supplemental materials were timely under Rule 26(e)(2) and non-prejudicial.	Weybosset claimed prejudice from late supplemental disclosure affecting trial preparation.	Discovery ruling affirmed; supplements were timely and non-prejudicial.

United Capitol Ins. Co. v. Kapiloff, 155 F.3d 488 (4th Cir. 1998) (role of supplemental jurisdiction and joinder contexts under §1367)
Grimes v. Mazda N. Am. Operations, 355 F.3d 566 (6th Cir. 2004) (§1367(b) interpretation and non-diverse party considerations)
Viacom Int'l v. Kearney, 212 F.3d 721 (2d Cir. 2000) (interpretation of supplemental jurisdiction boundaries)
State Nat'l Ins. Co. v. Yates, 391 F.3d 577 (5th Cir. 2004) (§1367(b) applicability to joinders by third parties)
Godin v. Schencks, 629 F.3d 79 (1st Cir. 2010) (standard for supplemental jurisdiction in the First Circuit)
Fondedile, S.A. v. C.E. Maguire, Inc., 610 A.2d 87 (R.I. 1992) (mutual assent to modification of contract; valid modification/waiver)
Rodriguez v. Doral Mortg. Corp., 57 F.3d 1168 (1st Cir. 1995) (1367(c) considerations and discretionary power)
Oneida Indian Nation of N.Y. v. Madison Cnty., 665 F.3d 408 (2d Cir. 2011) (§1367(c) not mandating dismissal when grounds exist to retain jurisdiction)