Williams v. Georgetown University Alumni & Student Federal Credit Union
Civil Action No. 2024-2672
D.D.C.Jun 10, 2025Background
- Riyan Williams borrowed approximately $42,000 from the Georgetown University Alumni & Student Federal Credit Union (the Credit Union) to purchase a car in 2024.
- Williams disputed the validity of the debt, arguing that his loan applications (including his Social Security Number) constituted assets for the Credit Union, offsetting the debt.
- Williams sued the Credit Union in D.C. Superior Court, alleging both state law violations and federal law breaches (Truth in Lending Act and Fair Debt Collection Practices Act).
- The Credit Union removed the case to federal court on the basis of federal question jurisdiction due to these federal claims.
- Williams then sought to amend his complaint, removing all federal claims and invoking only D.C. state law, and moved to remand the case back to Superior Court.
- The Credit Union opposed remand, citing the presence of federal claims in the original complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to Amend Complaint | Williams can amend as a matter of right | No significant objection; procedural issue | Granted: Plaintiff may amend |
| Federal Question Jurisdiction | Case is about D.C. law after amendment | Original complaint had federal claims, supporting removal | Jurisdiction lost after amendment |
| Remand to State Court | No federal subject matter jurisdiction | Federal jurisdiction existed at time of removal | Remand required |
| Applicability of "Royal Canin" Ruling | Amended complaint controls jurisdiction | Precedent prior to Royal Canin allowed discretion | Royal Canin governs; remand mandated |
Key Cases Cited
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (discussing supplemental jurisdiction over state law claims when federal courts have federal question jurisdiction)
- Rep. of Venezuela v. Philip Morris Inc., 287 F.3d 192 (D.C. Cir. 2002) (requirement to remand when federal court lacks jurisdiction over removed case)
- Shekoyan v. Sibley Int’l, 409 F.3d 414 (D.C. Cir. 2005) (court discretion to retain/state claims after federal claims are dismissed, as modified by Royal Canin)
- Edmondson & Gallagher v. Alban Towers Tenants Ass’n, 48 F.3d 1260 (D.C. Cir. 1995) (supplemental jurisdiction standards before Royal Canin)