Kimberly Hunt-Brown v. New Mexico General Services Department, et al.

Summary

The United States District Court for the District of New Mexico grants Plaintiff Kimberly Hunt-Brown’s motion to remand her remaining New Mexico Human Rights Act disability-accommodation claim to state court. The court declines to exercise supplemental jurisdiction after granting summary judgment on all federal claims, concluding that comity and federalism outweigh concerns about judicial economy and the approaching trial date. The case is remanded to the First Judicial District Court for Santa Fe County, New Mexico.

Holdings

1. The district court declined to exercise supplemental jurisdiction over the remaining NMHRA claim because the federal claims had been dismissed and the interests of comity and justice favored allowing New Mexico courts to decide the state-law issue.
2. The approaching trial and prior federal-court proceedings did not provide compelling reasons to retain jurisdiction because remand would require few duplicative efforts.

Questions Presented

1. Whether the district court should exercise supplemental jurisdiction over the remaining NMHRA disability-accommodation claim after dismissing all federal claims.
2. Whether considerations of judicial economy, convenience, fairness, and comity supported remanding the remaining state-law claim to state court.

Disposition

remanded