Henry v. Southwest Airlines, 2:22-cv-00944

Plaintiff Louis Henry, a Texas domiciliary, purchased a roundtrip Southwest Airlines ticket and requested wheelchair assistance for pre-existing disabilities.
At New Orleans' Louis Armstrong International Airport on April 7, 2021, Southwest allegedly failed to provide the requested wheelchair; Henry fell while boarding and sustained injuries.
Henry sued in federal court on April 7, 2022, asserting federal claims (Title III of the ADA and the Air Carrier Access Act) and several state-law claims.
The court dismissed Henry’s ACAA and ADA claims on motion; only state-law claims remained.
Plaintiff conceded lack of complete diversity; Southwest is incorporated and headquartered in Texas, and Henry is domiciled in Texas.
The court concluded it lacked diversity jurisdiction and, exercising its discretion under 28 U.S.C. § 1367(c), declined supplemental jurisdiction and dismissed the case to state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence of diversity jurisdiction	Henry concedes there is no complete diversity.	Southwest is a Texas citizen (incorporated & principal place of business in Texas).	No diversity jurisdiction — both parties are Texas citizens.
Whether to exercise supplemental jurisdiction after dismissal of federal claims	Court should retain supplemental jurisdiction (citing Batiste and Newport) for judicial economy and convenience.	Court should decline supplemental jurisdiction because federal claims are dismissed and the case is in early stages.	Court declined to exercise supplemental jurisdiction under § 1367(c) after all federal claims were dismissed.
Applicability of Batiste/Newport (retain state claims)	Those cases support retaining jurisdiction where substantial judicial resources already expended.	Those cases are distinguishable; here little discovery/judicial effort and trial is months away.	Batiste/Newport distinguished; retention would be an abuse of discretion only in cases far advanced, which this is not.

MidCap Media Fin., L.L.C. v. Pathway Data, Inc., 929 F.3d 310 (5th Cir. 2019) (defines corporate citizenship rules under § 1332)
Hertz Corp. v. Friend, 559 U.S. 77 (2010) (establishes "nerve center" test for principal place of business)
Coury v. Prot, 85 F.3d 244 (5th Cir. 1996) (individual domicile controls citizenship for diversity)
Heggemeier v. Caldwell Cnty., Tex., 826 F.3d 861 (5th Cir. 2016) (district courts have broad discretion on supplemental jurisdiction)
Manyweather v. Woodlawn Manor, Inc., 40 F.4th 237 (5th Cir. 2022) (upholding district court's discretion to decline supplemental jurisdiction)
Batiste v. Island Records, Inc., 179 F.3d 217 (5th Cir. 1999) (retention of state claims may be abuse of discretion when trial imminent and substantial resources expended)
Newport, Ltd. v. Sears, Roebuck & Co., 941 F.2d 302 (5th Cir. 1991) (declining jurisdiction on eve of trial after extensive proceedings is an abuse of discretion)
Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (considerations for dismissing pendent state claims)
Noble v. White, 996 F.2d 797 (5th Cir. 1993) (recognizes district court discretion over supplemental jurisdiction)