Wood v. Cognex Corporation
1:25-cv-10023
D. Mass.May 21, 2025Background
- Andre Wood, plaintiff, was hired by BlackTree Technical Group as an independent contractor to work at Cognex Corp.
- Wood alleges he was terminated shortly after requesting medical leave due to a health condition.
- Wood claims he was subject to racially motivated abuse at Cognex when a coworker displayed a noose and threatened him.
- Wood filed suit in Massachusetts state court, initially alleging violations of state law; Cognex removed the suit to federal court.
- Wood amended his complaint to include federal claims under Title VII (against Cognex) and ADA (against BlackTree), as well as reasserting state law claims.
- Plaintiff moved to remand the case to state court, arguing the federal court lacked jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal Question Jurisdiction | No federal issue is presented | Federal claims are alleged | Court has original jurisdiction |
| Supplemental Jurisdiction | State claims don't share facts | Claims share same facts | Claims derive from common facts |
| Predominance of State Claims | State claims predominate | Federal claims predominate | State claims do not predominate |
| Waiver of Motion to Remand | No waiver | Waiver by amending complaint | Court addresses motion out of caution |
Key Cases Cited
- United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (federal court may exercise supplemental jurisdiction over state claims from a common nucleus of operative fact)
- Gunn v. Minton, 568 U.S. 251 (federal question jurisdiction standard)
- Rodriguez v. Doral Mortg. Corp., 57 F.3d 1168 (affirming federal court jurisdiction over Title VII and state employment law claims)
- Ayala Serrano v. Lebron Gonzalez, 909 F.2d 8 (liberal construction of pro se pleadings)