943 F. Supp. 2d 1125
D. Idaho2013Background
- In March 2013 this Court granted summary judgment on Sadid’s federal claims; the remaining state-law claims are tortious interference with contract, defamation, and intentional infliction of emotional distress (IIED).
- Defendants moved for summary judgment on the state-law claims; both parties asked the Court to retain jurisdiction to adjudicate them.
- ISU tenured professor Sadid (1994–2009) was terminated after NOCA and a grievance hearing; witnesses described fear and safety concerns but no direct threats.
- The grievance committee recommended reinstatement, but President Vailas terminated Sadid for cause, citing a toxic atmosphere and abusive conduct.
- Public press coverage followed Sadid’s termination, and Garner issued statements; ISU Bengal published articles suggesting political aspects to the firing.
- The Court retained jurisdiction over the state-law claims and proceeded to rule on the pending motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retain supplemental jurisdiction over state-law claims | Sadid and Garner requested retention. | Same, to avoid piecemeal appeals. | Yes, jurisdiction retained. |
| Whether IIED claim is viable | Sadid alleges extreme conduct surrounding termination. | Termination not sufficiently extreme. | IIED claim not viable. |
| Whether third-party tortious interference with contract exists | Defendants interfered with Sadid’s contract via ISU actions. | ISU acted within employment scope; cannot be third party. | Dismissed; no third-party interference. |
| Defamation claims against Beard and Garner | Garner and Beard defamed Sadid; Beard forwarded a minority report; Garner’s statements to media. | Beard’s conduct lacks evidence; Garner’s statements are either true or opinion; defenses apply. | Beard claim granted to summary judgment for Beard; Garner defamation claim survives in part for trial (truth/opinion; damages; per se defamation considerations). |
| Motion to amend by defendants | Defendants should be allowed to add defenses. | Good-cause standard should apply; delays excused. | Motion to amend denied. |
Key Cases Cited
- Satey v. JPMorgan Chase & Co., 521 F.3d 1087 (9th Cir. 2008) (court-discussed supplemental jurisdiction and related concepts)
- Trustees of Construction Indus. & Laborers Health & Welfare Trust v. Desert Valley Landscape & Maintenance, Inc., 333 F.3d 923 (9th Cir. 2003) (retention of jurisdiction when state-law claims share facts with federal claims)
- Ostrander v. Farm Bureau Mut. Ins. Co. of Idaho, Inc., 851 P.2d 946 (Idaho 1993) (no tortious interference with contract when actions are within agent’s scope)