Ruffin v. Lockheed Martin Corporation, 1:13-cv-02744

Ruffin, an African-American woman, was hired by Lockheed in April 2008 as a Senior Systems Engineer and reported to white supervisors.
She faced repeated alleged harassment and workplace tensions from co-workers and supervisors, including a PIP in Oct 2008 due to attendance and a relocation that affected her finances.
Ruffin alleged a hostile work environment and taunting incidents, leading to ongoing performance reviews and discipline through 2010.
She filed a discrimination charge with the EEOC on July 6, 2011, while employed; she later filed for bankruptcy in Feb 2012 during the EEOC investigation.
Ruffin listed a few prior lawsuits in her bankruptcy petition and received a discharge on May 31, 2012; in March 2013 she obtained a right-to-sue letter from the EEOC.
Ruffin sued Lockheed in Maryland state court on June 14, 2013; Lockheed removed the case to federal court on Sept 17, 2013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has jurisdiction over Ruffin's claims.	Ruffin contends jurisdiction exists; seeks remand to state court.	Lockheed argues proper removal and federal jurisdiction via ADA claim.	The court lacks jurisdiction; dismissal granted due to bankruptcy-trustee standing.
Whether removal was proper given notice/address issues.	Ruffin argues notice sent to wrong address warrants remand.	Lockheed mailed notice to Ruffin's complaint address; good-faith effort suffices.	Removal proper; no remand required.
Whether Ruffin's state-law claims fall within supplemental jurisdiction.	Claims arise under state law; should be heard in state court.	Claims relate to the same nucleus of operative facts as the federal ADA claim.	Court retained supplemental jurisdiction; moot due to lack of jurisdiction on the main claim.
Whether the bankruptcy estate can authorize Ruffin to pursue the claims.	Trustee may substitute as plaintiff if needed.	Only the bankruptcy trustee may pursue estate claims; Ruffin lacks standing.	Ruffin lacks standing; case must be dismissed.
Whether the court should delay ruling to allow trustee intervention.	Delay to permit substitution may salvage claims.	No basis to delay; trustee intervention not shown.	Not addressed; dismissal based on lack of standing.

Md. Stadium Auth. v. Ellerbe Becket, Inc., 407 F.3d 255 (4th Cir. 2005) (removal statutes must be strictly construed in federalism concerns)
Caterpillar Inc. v. Williams, 482 U.S. 386 (U.S. Supreme Court 1987) (determines whether a claim arises under federal law for removal)
Verizon Maryland, Inc. v. Global NAPS, Inc., 377 F.3d 355 (4th Cir. 2004) (look to face of complaint to decide federal-question jurisdiction)
Rosmer v. Pfizer Inc., 263 F.3d 110 (4th Cir. 2001) (claims are part of same case or controversy if arising from common nucleus of operative facts)
Frye v. Pioneer Logging Mach., Inc., 555 F. Supp. 730 (D.S.C. 1983) (court may exercise supplemental jurisdiction when related by common facts)
Arnold v. CSX Hotels, Inc., 212 F. Supp. 2d 634 (S.D. W. Va. 2002) (good faith effort to give removal notice can satisfy §1446(d))
National Am. Ins. Co. v. Ruppert Landscaping Co., Inc., 187 F.3d 439 (4th Cir. 1999) (bankruptcy trustee stands to sue on estate claims)