American Association of University Professors, Bradley University Chapter et al. v. Bradley University

Summary

The United States District Court for the Central District of Illinois dismissed without prejudice the plaintiffs’ breach-of-contract claim against Bradley University. The court held that the contract claim did not form part of the same case or controversy as the plaintiff’s 42 U.S.C. § 1981 race-discrimination claim and, alternatively, that the state-law claim substantially predominated. The remainder of the case was referred to the magistrate judge for further case management.

Holdings

1. The state-law breach-of-contract claim and the federal § 1981 race-discrimination claim did not form part of the same case or controversy because they did not derive from a common nucleus of operative fact.
2. Even assuming the claims formed part of the same case or controversy, the court would decline supplemental jurisdiction over Count One because the breach-of-contract claim substantially predominated over the federal § 1981 claim.

Questions Presented

1. Whether the state-law breach-of-contract claim and the federal § 1981 race-discrimination claim formed part of the same case or controversy so that supplemental jurisdiction existed under 28 U.S.C. § 1367(a).
2. Whether, even if the claims were sufficiently related, the state-law breach-of-contract claim substantially predominated over the federal claim such that the court could decline supplemental jurisdiction under 28 U.S.C. § 1367(c)(2).

Disposition

dismissed