Nadesan v. Citizens Financial Group
673 F. App'x 47
2d Cir.2016Background
- Plaintiff Revindran Nadesan, a Singapore national, sued Citizens Financial Group and several individual supervisors alleging race discrimination and retaliation under 42 U.S.C. § 1981 and the Connecticut Fair Employment Practices Act, plus related state common-law claims.
- Complaint repeatedly described plaintiff as a “Singapore National” and asserted differential treatment by coworkers and supervisors.
- Plaintiff alleged he filed a discrimination complaint with the Connecticut CHRO and that two individual defendants knew of that complaint.
- The district court dismissed the federal claims for failure to state a § 1981 discrimination and retaliation claim, retained supplemental jurisdiction over the state-law claims, and dismissed those claims on the merits.
- Plaintiff appealed the dismissals and argued the district court abused its discretion by exercising supplemental jurisdiction and by failing to grant leave to amend; he conceded he never requested leave to amend in district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint states a § 1981 race-discrimination claim | Nadesan: treated differently because of his Singapore nationality, which he contends falls within § 1981’s protection for ancestry/ethnic characteristics | Defendants: alleged discrimination was based on national origin/place of origin, which § 1981 does not cover | Court: Dismissed § 1981 discrimination claim — allegations showed national origin, not race/ancestry under § 1981 |
| Whether complaint states a § 1981 retaliation claim | Nadesan: filing CHRO complaint and known to some defendants produced adverse actions | Defendants: complaint lacks factual detail linking CHRO complaint to adverse employment action | Court: Dismissed § 1981 retaliation claim — facts insufficient to plausibly show adverse action causally tied to protected activity |
| Whether district court abused discretion by retaining supplemental jurisdiction over state-law claims after dismissing federal claims | Nadesan: district court should have dismissed state claims once federal claims were gone | Defendants: exercise of supplemental jurisdiction was appropriate given overlapping facts and no unsettled state-law issues | Court: No abuse of discretion — judicial economy, convenience, fairness, and comity supported retaining jurisdiction |
| Whether district court erred by denying leave to amend complaint | Nadesan: should have been allowed to amend to cure pleading defects | Defendants: plaintiff never sought leave to amend in district court | Court: No error — plaintiff conceded he never requested leave; court did not abuse discretion |
Key Cases Cited
- Littlejohn v. City of New York, 795 F.3d 297 (2d Cir.) (retaliation prima facie and pleading standards on a motion to dismiss)
- Saint Francis Coll. v. Al-Khazraji, 481 U.S. 604 (race in § 1981 excludes mere national origin)
- Delaney v. Bank of Am. Corp., 766 F.3d 163 (2d Cir.) (standards for exercising supplemental jurisdiction)
- Marcus v. AT&T Corp., 138 F.3d 46 (2d Cir.) (general rule to dismiss state claims when federal claims are dismissed pretrial)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (values guiding discretionary exercise of supplemental jurisdiction)