R&L Carriers Shared Services, LLC v. Utah Labor Commission and Jaceson Maughan

Summary

The United States District Court for the District of Utah grants the Utah Labor Commission and its commissioner’s motion to dismiss R&L Carriers Shared Services, LLC’s challenge to Utah’s occupational-safety administrative process. The court holds that the Seventh Amendment has not been incorporated against the states and therefore cannot support the plaintiff’s claims concerning a jury trial in state administrative proceedings or its related 42 U.S.C. § 1983 claim. The court declines supplemental jurisdiction over the Utah constitutional claim and dismisses the remaining declaratory and injunctive relief claim.

Holdings

1. The Seventh Amendment does not apply to individual states and has not been incorporated through the Fourteenth Amendment.
2. Because the Seventh Amendment does not apply to the states, Plaintiff's allegation that Defendants violated a Seventh Amendment right by enforcing the Utah Occupational Safety and Health Act cannot support its § 1983 claims.
3. The court declined to exercise supplemental jurisdiction over Plaintiff's state constitutional claim after dismissing the federal claims.

Questions Presented

1. Whether the Seventh Amendment applies to the states through the Fourteenth Amendment and provides a jury-trial right in the Utah Labor Commission's administrative proceedings.
2. Whether the alleged denial of a Seventh Amendment jury-trial right supports a claim under 42 U.S.C. § 1983.
3. Whether the court should exercise supplemental jurisdiction over Plaintiff's claim that the Utah Occupational Safety and Health Act violates the Utah Constitution.
4. Whether Plaintiff was entitled to declaratory or injunctive relief after dismissal of the underlying federal and state claims.

Disposition

dismissed