Kenneth L. Lawson v. University of Hawaii, et al.

Summary

The United States District Court for the District of Hawaii granted in part and denied in part Kenneth L. Lawson’s Rule 12(c) motion for judgment on the pleadings concerning Camille Nelson’s defamation and intentional infliction of emotional distress counterclaims. The court dismissed the counterclaims because they lacked an independent basis for federal jurisdiction and the court declined to exercise supplemental jurisdiction over them under 28 U.S.C. § 1367(c)(4). The court did not reach Lawson’s remaining arguments concerning judicial notice, litigation privilege, limitations, or pleading sufficiency.

Holdings

1. Nelson's defamation and intentional infliction of emotional distress counterclaims were permissive rather than compulsory because their essential facts were not sufficiently logically related to Lawson's federal constitutional claims.
2. No independent basis for federal subject-matter jurisdiction existed over Nelson's counterclaims.
3. The court declined to exercise supplemental jurisdiction over Nelson's permissive counterclaims under 28 U.S.C. § 1367(c)(4) and dismissed the counterclaim on jurisdictional grounds.

Questions Presented

1. Whether Nelson's defamation and intentional infliction of emotional distress counterclaims were compulsory or permissive under Federal Rule of Civil Procedure 13.
2. Whether the federal court had an independent basis for subject-matter jurisdiction over Nelson's state-law counterclaims.
3. Whether the court should exercise supplemental jurisdiction over the permissive state-law counterclaims under 28 U.S.C. §§ 1367(a) and 1367(c)(4).

Disposition

dismissed