Phillips v. Mabus, Civil Action No. 2011-2021

Sebastian Phillips founded Marine Design Dynamics, Inc. (MDD), a naval‑architecture firm that performed energy‑conservation work for the Navy and as a subcontractor to CSC on the OPLOG program.
In 2011 four MDD employees left and allegedly formed or joined competing entities; plaintiffs allege one ex‑employee spread false rumors that MDD double‑billed, and that Navy officials redirected MDD’s OPLOG work to the departing employees.
Plaintiffs sued federal Navy officials (federal constitutional claims) and four former MDD employees (state common‑law claims for breach of fiduciary duty, defamation, and civil conspiracy).
The Court dismissed all federal claims and claims against one individual (Miller) in a 2019 opinion; remaining state‑law claims target three individual defendants (Mazzocco, Muras, Stammnitz).
Defendants moved to dismiss the remaining state‑law claims and argued the Court should decline supplemental jurisdiction; the Court denied the motion and retained supplemental jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the state‑law claims form part of the same Article III case or controversy?	The state claims arise from the same facts and events as the federal claims.	(No effective contest in briefing.)	Yes; claims derive from a common nucleus of operative fact.
Do the state‑law claims raise novel or complex D.C. law issues that warrant declining jurisdiction?	No; breach of fiduciary duty, defamation, and conspiracy are settled areas of D.C. law.	The factual scenario is unusual and thus presents unsettled legal questions.	No; the legal questions are not novel or complex such that §1367(c)(1) requires declination.
Should the Court decline supplemental jurisdiction now that federal claims were dismissed?	Retention is warranted by judicial economy, convenience, and the court’s familiarity after 10+ years of litigation.	Court should follow the “favored course” and dismiss the pendent state claims without prejudice.	Court exercises discretion to retain supplemental jurisdiction (§1367) based on case history, efficiency, and comity.
Motion to dismiss the remaining state‑law claims against the three individual defendants?	Plaintiffs say claims are adequately pleaded and previously considered in related rulings.	Defendants seek dismissal under Rule 12(b)(1) and §1367 grounds.	Motion denied; Court will adjudicate the state‑law claims on the merits under retained supplemental jurisdiction.

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966) (pendent jurisdiction test and discretionary factors)
Carnegie–Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (factors favoring dismissal of pendent state claims pretrial)
Shekoyan v. Sibley Int'l, 409 F.3d 414 (D.C. Cir. 2005) (usual case weighs toward dismissing state claims when federal claims are dismissed)
Edmondson & Gallagher v. Alban Towers Tenants Ass'n, 48 F.3d 1260 (D.C. Cir. 1995) (supplemental‑jurisdiction discretionary analysis)
Powers v. United States, 783 F.3d 570 (5th Cir. 2015) (factual novelty does not necessarily create novel legal question)
Phillips v. Spencer (Phillips III), 390 F. Supp. 3d 136 (D.D.C. 2019) (prior district‑court rulings on related claims and defendants)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for accepting allegations as true)
McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178 (1936) (plaintiff bears burden of establishing subject‑matter jurisdiction)