When I was a senior at Beachwood High School, we were allowed to leave for lunch and many of us headed to Beachwood Place Mall. Way back then, the food court would always been jammed packed, and it was impossible to find a table in the center court. But the Chick-fil-A, well, it had a bunch of its own tables inside its space. The problem was, you could just pick up Antonio’s Pizza, an Incredible Spud stuffed baked potato, or McDonald’s and head into Chick-fil-A to eat … except if someone in your group order a box of nuggets or a lemonade, you got to come in with the rest of the outside food. This is exactly what supplemental jurisdiction is.
State law claims cannot typically be brought independently in federal court unless the case meets certain jurisdictional requirements. It is like trying to sit at Chick-fil-A’s tables without buying anything from their menu. State law claims, such as defamation or breach of contract, fall under state courts’ general jurisdiction. However, if your federal claim acts as the “box of nuggets,” then your related state law claims can “tag along” under supplemental jurisdiction. This allows the federal court to hear all related claims together, saving time and ensuring consistent outcomes.
Supplemental jurisdiction plays a critical role in many employment law cases. Under 28 USC § 1367(a), a federal court may exercise supplemental jurisdiction over state law claims if they are closely related to the federal claims and form part of the same case or controversy. In Frank L. Johnson v. Builders FirstSource Southeast Group LLC No. 23-1530, the United States Court of Appeals for the Fourth Circuit upheld a district court’s decision to retain jurisdiction over a state law defamation claim even after dismissing a federal discrimination claim. This case highlights the importance of supplemental jurisdiction and how it affects employees navigating complex legal battles.
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Can a Federal Court Hear My State Law Claim?
If you face employment discrimination or were wrongfully terminated, you might wonder whether your related state law claims, such as defamation, breach of contract or claims under state employment laws, can stay in the same federal lawsuit. The answer is often yes—but it depends on whether your state law claims connect closely to your federal claims.
The Fourth Circuit Court of Appeals, in Johnson, affirmed that district courts have “wide latitude” in deciding whether to retain jurisdiction over state claims when federal claims are dismissed. The Court held that a district court must weigh factors like judicial economy, fairness to the parties, and whether the state law claim raises issues of federal policy. The district court in Johnson found that retaining the defamation claim was convenient and fair since the federal claim had already been closely tied to the same facts.
If you pursue a federal employment law claim, your state law claims may stay in the same courtroom, saving time and resources. However, retaining supplemental jurisdiction is not guaranteed. Hiring an experienced attorney is essential to navigate this process effectively.
What Happens If My Federal Claim Is Dismissed?
Employees often worry about what happens to their state claims if their federal claims are dismissed. In Johnson, the district court dismissed the federal discrimination claim but retained jurisdiction over the state defamation claim. The Fourth Circuit Court of Appeals upheld this decision, noting that supplemental jurisdiction allows courts to “sensibly accommodate a range of concerns and values.”
The Court held that judicial economy and fairness to the parties warranted keeping the case in federal court. If you are an employee in a similar situation, this means you may still have a chance to pursue justice for related state law violations—but only if the court exercises its discretion to retain jurisdiction.
How Can I Prove Defamation in Employment Cases?
The Johnson case also sheds light on the challenges of proving defamation in employment cases. Johnson argued that his employer defamed him by issuing a written disciplinary warning and terminating his employment for actions he claimed he did not commit. However, the Fourth Circuit Court of Appeals affirmed that there was no evidence of false statements being published and rejected Johnson’s arguments of defamation by insinuation.
South Carolina law defines defamation as a statement that “tends to harm the reputation of another as to lower him in the estimation of the community or deter third persons from associating or dealing with him.” To win a defamation claim, an employee must prove:
- A false and defamatory statement was made.
- The statement was published to a third party.
- The publisher was at fault.
- The statement caused harm or was actionable on its face.
In Johnson, the district court found that the statements made by the employer were not false, a critical element of any defamation claim. If you believe you have been defamed, work with an experienced employment lawyer who can help you gather evidence and build a strong case.
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How Do I Find the Best Attorney for My Employment Case?
If this question brought you here, Spitz, The Employee’s Law Firm is the answer.
Spitz is one of the largest law firms in the United States dedicated solely to protecting employees’ rights. This focus gives us unmatched resources to fight for justice in complex employment law cases. We offer a free initial consultation and a no-fee guarantee, so you can pursue your case without worrying about upfront costs. Our attorneys bring vast trial experience, empathy, and a history of great results.
Do not let an employer’s unfair actions go unchallenged. Call us today to learn how we can help. Your rights matter, and we are ready to fight for them.
Employment Lawyer Disclaimer
This employment lawyer blog provides general information about employment discrimination, harassment, and wrongful termination. It should not be taken as legal advice. If you believe you are a victim of workplace discrimination, wrongful termination, or other employment law violations, consult with a qualified employment lawyer for personalized advice. No promises are being made, and this blog is a legal advertisement.