Rivera-Nazario v. Corporacion del Fondo del Seguro
3:14-cv-01533
D.P.R.Sep 27, 2016Background
- Licensed chiropractors and clinics sued CFSE and several officials in 2014 alleging Sherman Act, constitutional, and Puerto Rico law violations; the Amended Complaint included a state-law negligence claim (Article 1802) tied to Acts 45 and 194.
- The Court dismissed several federal constitutional claims and First Amendment retaliation claims as to the individual co-defendants (Lastra-González, Díaz-Trancón, Rivera-Serrano, Colón-Grau).
- After a renewed motion, the Court dismissed Plaintiffs’ Sherman Act claims with prejudice, leaving only a First Amendment claim against CFSE and Estrada and state-law claims against all Defendants.
- Co-Defendants moved to dismiss the remaining state-law claims against them, arguing the Court should decline supplemental jurisdiction because no federal claims remain against those co-defendants.
- Plaintiffs opposed, asserting federal jurisdiction remained and seeking to strike the dismissal argument as untimely; Co-Defendants replied that jurisdictional defenses are not waived.
- The Court granted the motion to dismiss the state-law claims against the co-defendants (without reaching merits), concluding it would decline supplemental jurisdiction and denied the motion to strike.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should retain supplemental jurisdiction over state-law claims against co-defendants after federal claims against them were dismissed | Plaintiffs contend a federal claim still exists in the action and jurisdiction therefore remains; they also argue defendants waived certain defenses | Co-Defendants argue no federal claims remain against them and the Court should decline supplemental jurisdiction; jurisdictional defenses cannot be waived | Court declined to exercise supplemental jurisdiction and dismissed state-law claims against co-defendants without prejudice |
| Whether the motion to dismiss state-law claims for failure to state a claim should be stricken as untimely | Plaintiffs: motion to dismiss on merits should be stricken because it could have been raised earlier | Co-Defendants: jurisdictional defenses are never waived and can be raised now | Court denied motion to strike; relied on jurisdictional grounds so timeliness irrelevant |
| Whether the state-law claims are sufficiently related to the remaining federal claim to justify supplemental jurisdiction | Plaintiffs did not adequately show the relation | Co-Defendants: the remaining First Amendment claim is linked to CFSE/Estrada and co-defendants were not tied to that conduct | Court found the state claims were at best indirectly related and decline to retain jurisdiction |
| Whether factors (fairness, judicial economy, convenience, comity) favor retaining jurisdiction | Plaintiffs implicitly argue for efficiency by keeping all claims in federal court | Co-Defendants argue considerations weigh against retention given early dismissal of federal claims and local-law nature of state claims | Court concluded those factors weigh against retention and dismissed state-law claims without prejudice |
Key Cases Cited
- Camelio v. Am. Fed'n, 137 F.3d 666 (1st Cir. 1998) (factors for exercising supplemental jurisdiction and prudential considerations)
- Desjardins v. Willard, 777 F.3d 43 (1st Cir. 2015) (court may decline supplemental jurisdiction after dismissal of federal claims)
- Rodríguez v. Doral Mortgage Corp., 57 F.3d 1168 (1st Cir. 1995) (presumption favoring dismissal of pendent state-law claims when federal claims are disposed of early)
- Golas v. HomeView Inc., 106 F.3d 1 (1st Cir. 1997) (reluctance to exercise jurisdiction over pendent parties and prudential analysis)
- United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (avoid needless decisions of state law; comity principles)
- McCulloch v. Velez, 364 F.3d 1 (1st Cir. 2004) (subject-matter jurisdiction defenses cannot be waived)