## Facts

- Donna L. Page, a Black female employee, sued her employer, Executive Software North America, Inc., and two individual defendants, alleging workplace discrimination tied to required study of Scientology teachings.
- Page alleged that after refusing to participate, she was accused of work errors, denied a chance to contest them, and terminated, allegedly as a pretext for discrimination based on religion, sex, and race.
- Page filed in California state court asserting federal Title VII claims and multiple state-law claims (including state constitutional and statutory anti-discrimination claims).
- Defendants removed the case to federal court based on federal-question jurisdiction over the Title VII claims.
- The federal district court remanded the pendent state-law claims to state court, reciting general considerations (predominance, novelty/complexity, jury confusion, judicial effort) without tying them to a specific statutory basis or to the case’s particulars.
- Defendants sought a writ of mandamus from the Ninth Circuit to require the district court to keep the state-law claims.

## Issues

1. Whether, after enactment of 28 U.S.C. § 1367, a district court may decline supplemental jurisdiction based solely on generalized discretionary factors, or must first identify one of the four statutory grounds in § 1367(c).
2. Whether mandamus is available to correct a district court’s remand of supplemental state-law claims where the court did not apply § 1367(c)’s required framework.

## Decision

- The Ninth Circuit granted mandamus and directed the district court to apply the proper § 1367(c) analysis before declining supplemental jurisdiction.
- The court held that § 1367(c) requires the district court to identify which enumerated circumstance authorizes declination and to articulate that basis in its order.
- The court held that reliance on § 1367(c)(4) requires a heightened showing: the district court must identify “exceptional circumstances” and state the “compelling reasons” for declining jurisdiction.
- The court concluded the district court committed clear legal error by treating supplemental-jurisdiction declination as open-ended discretion untethered to § 1367(c).
- A dissent would have treated § 1367 as leaving broader discretion and would have denied mandamus.

## Legal Principles

- A district court may decline supplemental jurisdiction only if one of the circumstances in 28 U.S.C. § 1367(c)(1)–(4) is satisfied.
- After identifying a valid § 1367(c) basis, the court may consider judicial economy, convenience, fairness, and comity in deciding whether to retain supplemental claims.
- Orders declining supplemental jurisdiction must provide a reasoned, case-specific explanation; boilerplate references to general factors are insufficient.
- Section 1367(c)(4) is narrow: declination requires “exceptional circumstances” and “other compelling reasons,” which must be expressly stated.
- Mandamus may issue to correct a district court’s misapprehension of § 1367(c)’s limits where the error is clear and ordinary review is inadequate.

## Conclusion

The Ninth Circuit required district courts declining supplemental jurisdiction under § 1367(c) to identify a specific statutory ground and provide a case-specific explanation, with a heightened articulation requirement when relying on § 1367(c)(4), and granted mandamus because the remand order failed to comply with that framework.


Exec. Software N. Am., Inc. v. U.S. Dist. Ct. for Cent. Dist. of Cal., 15 F.3d 1484 (9th Cir. 1994)