Chelsey Simmons v. OSF Healthcare Systems and Jomel Labayog

Summary

The court granted Defendant Jomel Labayog’s motion to dismiss claims under the Illinois Human Rights Act and Illinois Gender Violence Act. After dismissing the federal Title VII claim, the court relinquished supplemental jurisdiction and dismissed the remaining state-law claims without prejudice, allowing the plaintiff fourteen days to amend.

Holdings

1. When all federal claims are dismissed before trial, the district court should generally relinquish supplemental jurisdiction over the remaining state-law claims and dismiss them without prejudice.
2. The court need not reach Labayog's other arguments because it lacked subject matter jurisdiction over the remaining claims.

Questions Presented

1. Whether the district court should retain supplemental jurisdiction over the Illinois Human Rights Act and Illinois Gender Violence Act claims after dismissal of the sole federal claim.
2. Whether Labayog's motion to dismiss should be granted without reaching his other arguments.

Disposition

dismissed