T.C. v. City of San Diego
- Proceeding
- district
- Area
- civil
- Panel
- Jinsook Ohta (author)
Analysis
The court reviewed the plaintiff's state law claims for breach of contract, breach of the covenant of good faith and fair dealing, and intentional infliction of emotional distress, which were taken under submission following the dismissal of federal injunctive claims under Younger abstention. The court ordered that it would retain supplemental jurisdiction over these state claims but stay them pending the completion of the related state court adjudication.
| What the court decided | The model |
|---|---|
The court exercised supplemental jurisdiction over the plaintiff's state law claims (breach of contract, breach of the covenant of good faith and fair dealing, and intentional infliction of emotional distress).“After reviewing this matter, the Court has decided to exercise its supplemental jurisdiction over Plaintiff’s state law claims for breach of contract, breach of the covenant of good faith and fair dealing, and intentional infliction of emotional distress.” | agree with court The court correctly identified that the state claims arose from the same common nucleus of operative facts as the federal claims. Under 28 U.S.C. § 1367(c), a district court has discretion to retain supplemental jurisdiction. The court cited Arroyo v. Rosas, a Ninth Circuit case, to support the finding that the claims were sufficiently related. Retaining jurisdiction is a permissible exercise of discretion when the claims are factually intertwined with the federal claims. |
The court stayed the plaintiff's state law claims pending the resolution of the related state court adjudication.“As with Plaintiff’s federal claims for damages, the Court will stay these three state law claims pending resolution of the related state court adjudication.” | agree with court The court applied the principle from Gilbertson v. Albright, a Ninth Circuit case, which holds that when injunctive relief claims are dismissed under abstention principles, related damages actions should be stayed until state proceedings are completed. Since the federal injunctive claims were previously dismissed under Younger abstention, staying the related state law claims is consistent with established circuit precedent to avoid duplicative litigation and respect state court proceedings. |
The order itself: sound — The order is concise but legally sound. It correctly identifies the relevant statute for supplemental jurisdiction and cites appropriate Ninth Circuit precedent for both the retention of jurisdiction (Arroyo) and the stay of proceedings (Gilbertson). The reasoning directly addresses the issue taken under submission and applies the correct legal standards for abstention-related stays.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 T.C., Case No.: 3:23-cv-02225-JO-MMP 12 Plaintiff, 13 v. ORDER STAYING SUPPLEMENTAL STATE LAW 14 CITY OF SAN DIEGO, a Public Entity; CLAIMS CHIEF OF POLICE DAVE NISLEIT, 15 individually and in his official capacity, as 16 Chief of Police at SDPD for City of San Diego; MARA W. ELLIOTT, individually 17 and in her official capacity, as City 18 Attorney for City of San Diego; JESSE ZALDIVAR, individually and in his 19 official capacity, as SDPD Investigator for 20 City of San Diego; JOSHUA H. KAY, individually and in his official capacity, as 21 City Attorney for City of San Diego; 22 JEFFREY A. BROOKER, individually and in his official capacity, as City 23 Attorney for City of SanDiego; 24 PATRICIA MIRANDA, individually and in her official capacity, as Deputy City 25 Attorney for City of SanDiego; and DOES 26 1 through 10, inclusive, 27 Defendants. 28 1 On December 6, 2023, Plaintiff T.C. filed a complaint, alleging eight different 2 causes of action under federal and state law seeking both injunctive relief and monetary 3 damages against the City of San Diego and the following individuals in their individual 4 and official capacity: City Attorneys for the City of San Diego Mara W. Elliott, Joshua H. 5 Kay, Jeffrey A. Brooker, and Patricia Miranda, Chief of Police Dave Nisleit, San Diego 6 Police Department Investigator Jesse Zaldivar, and DOES 1 through 10. Dkt. 1. 7 On December 15, 2023, the Court held oral argument. Dkt. 8. For the reasons stated 8 on the record at the oral argument, the Court dismissed without prejudice Plaintiff’s first 9 and fifth claims seeking injunctive relief pursuant to Younger abstention principles and 10 stayed Plaintiff’s second, third, fourth, and fifth claims requesting monetary damages under 11 42 U.S.C. § 1983. Dkt. 9. At this hearing, the Court took under submission the issue of 12 whether it should dismiss or retain jurisdiction over Plaintiff’s state law claims for breach 13 of contract, breach of the covenant of good faith and fair dealing, and intentional infliction 14 of emotional distress (his sixth, seventh, and eighth claims). Id. 15 After reviewing this matter, the Court has decided to exercise its supplemental 16 jurisdiction over Plaintiff’s state law claims for breach of contract, breach of the covenant 17 of good faith and fair dealing, and intentional infliction of emotional distress. 28 U.S.C. § 18 1367(c). Because these claims “derive from [the same] common nucleus of operative 19 fact[s]” as Plaintiff’s § 1983 claims, the Court exercises its discretion to retain jurisdiction. 20 Arroyo v. Rosas, 19 F.4th 1202, 1209 (9th Cir. 2021). As with Plaintiff’s federal claims 21 for damages, the Court will stay these three state law claims pending resolution of the 22 related state court adjudication. See Gilbertson v. Albright, 381 F.3d 965, 968 (9th Cir. 23 2004) (holding that where injunctive relief claims are dismissed due to abstention 24 principles, related “damages actions should be stayed until the state proceedings are 25 completed”). 26 / / / 27 / / / 28 1 This case will recommence after the parties have notified the Court of the completion 2 || of the state court adjudication. 3 IT IS SO ORDERED. 4 || Dated: March 13, 2024 5 6 Ho orgbfe Tinsook Ohta 7 United States District Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28