Mr. Roof and Solar, Inc. dba American Eagle Roofing v. Sequoia Roofing and Construction, Tyler Anderson, and Robert Williams

Summary

The United States District Court for the Eastern District of California dismissed Robert Williams’s counterclaims for breach of contract, unpaid wages, and waiting-time penalties. The court held that the counterclaims did not fall within its original jurisdiction and were not sufficiently related to the plaintiff’s copyright-infringement claim to support supplemental jurisdiction under 28 U.S.C. § 1367. The court also stated that it would decline supplemental jurisdiction even if it existed.

Holdings

1. The court lacked original subject matter jurisdiction over Williams's state-law counterclaims for breach of contract, unpaid wages, and waiting-time penalties.
2. The court lacked supplemental jurisdiction over Williams's counterclaims because the pleadings did not establish that the counterclaims and the copyright-infringement claim formed part of the same case or controversy.
3. Even if supplemental jurisdiction existed, the court would decline to exercise it under 28 U.S.C. § 1367(c).

Questions Presented

1. Whether the district court had original federal subject matter jurisdiction over Williams's state-law counterclaims for breach of contract, unpaid wages, and waiting-time penalties.
2. Whether the counterclaims fell within the court's supplemental jurisdiction under 28 U.S.C. § 1367(a) because they formed part of the same case or controversy as the copyright-infringement claim.
3. Whether the court should decline supplemental jurisdiction under 28 U.S.C. § 1367(c) even if supplemental jurisdiction existed.

Disposition

dismissed