Manyweather v. Woodlawn Manor
40 F.4th 237
| 5th Cir. | 2022Background
- The Manyweathers sued Woodlawn Manor in Louisiana state court, alleging negligence and gross negligence (wrongful death, loss of chance, survival) after their mother contracted COVID-19 at the facility; complaints also referenced ADA and Medicare/Medicaid rules.
- Woodlawn removed under 28 U.S.C. §§ 1441–1446, arguing federal-question jurisdiction because the PREP Act preempted the state claims (complete preemption) and, alternatively, that supplemental jurisdiction existed because plaintiffs had pleaded federal claims.
- Woodlawn moved to dismiss under the PREP Act, asserting immunity except for willful-misconduct claims (which, if asserted, must proceed in D.C. federal court under the Act).
- The magistrate judge and then the district court dismissed the ADA and Medicare/Medicaid claims and remanded the remaining state-law negligence claims to state court, concluding the PREP Act did not convert the negligence claims into federal questions and declining supplemental jurisdiction under 28 U.S.C. § 1367(c)(3).
- On appeal Woodlawn argued (1) the PREP Act completely preempted the negligence claims (so federal jurisdiction existed), (2) the plaintiffs had pleaded willful misconduct under the PREP Act, and (3) the district court should have retained supplemental jurisdiction.
- The Fifth Circuit affirmed: PREP Act does not completely preempt state-law negligence claims (per Mitchell), the petition did not plead PREP Act willful misconduct, and declining supplemental jurisdiction was not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PREP Act completely preempts state-law negligence claims (creates exclusive federal cause of action) | Manyweathers: claims are state-law negligence; no federal preemption | Woodlawn: PREP Act preempts/wholly displaces state negligence, supplying federal-question jurisdiction | Held: PREP Act does not completely preempt negligence claims (Mitchell controls); no federal-question jurisdiction |
| Whether the complaint pleaded PREP Act willful-misconduct (thus invoking exclusive federal scheme) | Manyweathers: pleadings allege negligence/gross negligence, not the narrow statutory willful-misconduct standard | Woodlawn: allegations (e.g., mother was “knowingly exposed”) suffice to allege willful misconduct under PREP Act | Held: Complaint does not plead willful misconduct as defined by PREP Act; defendant cannot rely on unpleaded theories to establish federal jurisdiction |
| Whether district court abused discretion by declining supplemental jurisdiction after dismissing federal claims | Manyweathers: remand appropriate; state courts should decide remaining state-law claims | Woodlawn: district court should have retained supplemental jurisdiction to decide state claims | Held: No abuse of discretion—common-law factors (judicial economy, convenience, fairness, comity) favored remand at pleading stage; §1367(c)(3) applied |
Key Cases Cited
- Mitchell v. Advanced HCS, L.L.C., 28 F.4th 580 (5th Cir. 2022) (rejected PREP Act complete preemption of state negligence claims)
- Est. of Maglioli v. All. HC Holdings, LLC, 16 F.4th 393 (3d Cir. 2021) (analyzed PREP Act immunity and willful-misconduct exception)
- Metro. Life Ins. Co. v. Taylor, 481 U.S. 58 (1987) (well-pleaded-complaint rule and complete-preemption corollary)
- Beneficial Nat’l Bank v. Anderson, 539 U.S. 1 (2003) (complete-preemption doctrine discussion)
- Louisville & Nashville R.R. Co. v. Mottley, 211 U.S. 149 (1908) (foundation of the well-pleaded-complaint rule)
- Aetna Health Inc. v. Davila, 542 U.S. 200 (2004) (framework for when federal statutory scheme supersedes state law claims)
- Heggemeier v. Caldwell County, 826 F.3d 861 (5th Cir. 2016) (standards and factors for declining supplemental jurisdiction under §1367)
- Reed v. Goertz, 995 F.3d 425 (5th Cir. 2021) (standard of review for federal-question jurisdiction determinations)