Clark v. IOWA STATE UNIVERSITY
643 F.3d 643
8th Cir.2011Background
- Clark was terminated from her clerk-typist position at Iowa State University on February 25, 2009.
- She sued ISU, the Board of Regents, and two ISU officials (Geoffroy and Callahan) alleging ADEA, ADA, freestanding due process and equal protection claims, and a state-law wrongful discharge claim.
- The district court dismissed the federal claims, dismissed the freestanding due process/equal protection claims, and held the ADA claim exhausted and applicable; ADEA claims were barred against the individual defendants; and the state-law claim against Geoffroy and Callahan was dismissed for lack of subject-matter jurisdiction.
- Clark sought relief under Rule 59/60 and proposed amendments; the district court denied both relief and amendments, citing prior rejections and prejudice to defendants.
- On appeal, the Eighth Circuit affirmed in part (freestanding due process dismissal; denial of post-judgment relief) but reversed and remanded on the state-law wrongful discharge claim against Geoffroy and Callahan in their individual capacities for lack of clarity on supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether freestanding due process/equal protection claims survive | Clark asserts freestanding due process/equal protection claims against state actors. | Defendants contend such claims fail without §1983 framework or state-law basis. | Dismissed; no viable freestanding federal due process/equal protection claims. |
| Whether ADA claim was properly dismissed | Clark contends ADA claim should proceed absent exhaustion issues. | Defendants argue ADA inapplicable to employment-practice claims/failed exhaustion. | Dismissed for failure to exhaust or inapplicability to the claim. |
| Whether ADEA claims can be asserted against Geoffroy and Callahan in their individual capacities | Clark argues individual-capacity ADEA claims should proceed. | Defendants argue Eleventh Amendment immunity and exhaustion/limitations bar individual-capacity claims. | Dismissed; individual-capacity ADEA claims barred. |
| Whether the district court had supplemental jurisdiction over state-law wrongful-discharge claims | Clark seeks state-law claims retained with federal claims under supplemental jurisdiction. | District court lacked jurisdiction if no federal claim remained; argued absence of original jurisdiction. | Remanded; district court properly dismissed federal claims but retained jurisdiction under 28 U.S.C. §1367 over pendent state-law claim for reconsideration. |
| Whether post-judgment and amendment rulings were correct | Clark challenges denial of Rule 59/60 relief and amendment. | Defendants argue no error given prior deficiencies and prejudice concerns. | Affirmed denial of post-judgment relief; remanded on jurisdictional issue; no abuse of discretion on amendments. |
Key Cases Cited
- Arbaugh v. Y & H Corp., 546 U.S. 500 (Supreme Court 2006) (when a court dismisses for lack of subject-matter jurisdiction, can consider supplemental jurisdiction under §1367)
- Webb v. Bladen, 480 F.2d 306 (4th Cir. 1973) (recognizes discretion to exercise supplemental jurisdiction in pendent-claim context)