Facts
- Rachel Wasserman worked for Potamkin Toyota, Inc.
- Wasserman alleged that she experienced sexual harassment at work.
- Wasserman left her job and sued in federal district court.
- Wasserman asserted federal claims under Title VII of the Civil Rights Act of 1964.
- Wasserman also brought related state-law claims under the Pennsylvania Human Relations Act (PHRA).
- In addition to naming Potamkin Toyota, Wasserman sued three Potamkin Toyota employees under the PHRA.
- The PHRA claims against the employees rested on the theory that the PHRA permits personal liability for individual employees.
- Defendants argued the court should refuse supplemental jurisdiction over the PHRA claims because the case raised a novel state-law question: whether the PHRA allows personal liability for individual employees.
Issues
- Should the federal district court decline supplemental jurisdiction under 28 U.S.C. § 1367(c)(1) over PHRA claims against individual employees because the existence of individual liability under the PHRA was allegedly a novel or complex question of Pennsylvania law?
Decision
- The court exercised supplemental jurisdiction over the PHRA claims.
- The court declined to dismiss or send the PHRA claims to state court solely because Pennsylvania law on individual PHRA liability was argued to be unsettled.
- The PHRA claims against the employer and the individual employees proceeded in the same federal action as the Title VII claims.
Legal Principles
- A federal court with original jurisdiction over federal claims may hear related state-law claims that are part of the same case or controversy. 28 U.S.C. § 1367(a).
- A court may decline supplemental jurisdiction if a state-law claim raises a novel or complex issue of state law, but the statute gives the court discretion rather than imposing a requirement. 28 U.S.C. § 1367(c)(1).
- The mere presence of an unresolved or disputed state-law question does not automatically justify declining supplemental jurisdiction when the state and federal claims arise from the same events and can be resolved together.
- In deciding whether to keep supplemental claims, courts consider practical factors such as efficiency, convenience, fairness, and avoidance of duplicative proceedings.
Conclusion
The district court retained supplemental jurisdiction over Wasserman’s PHRA claims, including those asserted against individual employees, concluding that the asserted uncertainty about whether the PHRA permits personal liability did not, by itself, require the federal court to decline jurisdiction under § 1367(c)(1) where the state and federal claims stemmed from the same alleged workplace conduct.