## Facts

- Manuel A. Iglesias served as the San Juan Agency Manager for Mutual Life Insurance Company of New York (MONY).
- After discussions about Iglesias’s retirement, MONY sent a letter dated February 9, 1989 stating that Iglesias would no longer be authorized to act as Agency Manager.
- Iglesias filed an administrative discrimination charge with Puerto Rico’s Anti-Discrimination Division on August 28, 1990.
- Iglesias filed his federal complaint on April 17, 1991, asserting Title VII and ADEA discrimination claims and related contract claims.
- During discovery, Iglesias admitted submitting overstated expense vouchers; MONY asserted a state-law counterclaim seeking restitution of the overpayments.
- The district court granted summary judgment to MONY on Iglesias’s discrimination and contract claims and dismissed MONY’s counterclaim as untimely.

## Issues

1. When did Iglesias’s Title VII and ADEA claims accrue for limitations purposes: at the time he received the February 9, 1989 termination notice or later?
2. Whether Iglesias’s discrimination claims were time-barred under the applicable administrative filing deadlines.
3. Whether summary judgment for MONY on Iglesias’s contract-based claims was proper on the record.
4. Whether the federal court had subject-matter jurisdiction over MONY’s state-law restitution counterclaim after dismissal of the federal claims, and, if not, whether dismissal should be without prejudice.

## Decision

- The First Circuit reviewed summary judgment de novo, viewing the record in the light most favorable to the nonmovant.
- The court affirmed summary judgment for MONY on Iglesias’s discrimination and contract claims.
- The court held that Iglesias received clear and unequivocal notice of termination no later than February 9, 1989, triggering the Title VII and ADEA filing periods.
- The court concluded Iglesias’s discrimination claims were untimely because he filed his administrative charge and federal action well beyond the applicable deadlines.
- The court vacated the dismissal of MONY’s counterclaim and remanded with instructions to dismiss the counterclaim without prejudice for lack of jurisdiction.

## Legal Principles

- Title VII and ADEA claims accrue when an employee receives clear and unequivocal notice of the adverse employment decision; later effects of that decision do not restart the limitations clock.
- In a deferral jurisdiction, Title VII and ADEA generally require filing an administrative charge within 300 days of the alleged unlawful practice.
- A federal court must confirm an independent basis for jurisdiction over a purely state-law counterclaim (e.g., diversity, including the amount-in-controversy requirement) or a valid basis for supplemental jurisdiction.
- When the federal claims providing original jurisdiction are dismissed and no independent jurisdictional basis supports the state-law counterclaim, the proper disposition is dismissal without prejudice for lack of subject-matter jurisdiction.

## Conclusion

The court held that Iglesias’s discrimination claims accrued upon MONY’s unequivocal termination notice and were barred by missed filing deadlines, affirmed dismissal of his contract claims, and required MONY’s state-law restitution counterclaim to be dismissed without prejudice because the federal court lacked subject-matter jurisdiction to decide it.


Iglesias v. Mut. Life Ins. Co. of N.Y., 156 F.3d 237 (1st Cir. 1998)