Executive Software North America, Inc. v. United States District Court for the Central District of California
United States Court of Appeals for the Ninth Circuit
24 F.3d 1545 (9th Cir. 1994)
Donna Page sued Executive Software North America (plaintiff) in state court, asserting two federal and three state discrimination claims. Executive Software removed the case to the U.S. District Court for the Central District of California (defendant), which then remanded the three state-law claims back to state court. The district court's remand order cited the general standards from United Mine Workers v. Gibbs and 28 U.S.C. § 1367 for exercising supplemental jurisdiction, but gave no case-specific reasons for declining jurisdiction in this particular case. Executive Software petitioned for a writ of mandamus to compel the district court to retain the state-law claims.
Whether a district court may decline supplemental jurisdiction over pendent state-law claims under 28 U.S.C. § 1367(c)(4) without specifically explaining why the circumstances of the case are exceptional and why balancing the Gibbs values compels declining jurisdiction.