Supplemental jurisdiction; 28 USC § 1367(a); Claim under the Fair & Just Treatment Clause of the Michigan Constitution (Const 1963, art I, § 17); Whether the district court should have declined supplemental jurisdiction; § 1367(c); Effect of the dismissal of all plaintiff’s federal claims; “Novel or complex issues of state law”

[This appeal was from the ED-MI.] The court held that under the circumstances of this case, the district court abused its discretion by exercising supplemental jurisdiction over plaintiff-Williams’s claim under the Fair and Just Treatment Clause of the Michigan Constitution where the federal claims were dismissed and “novel or complex issues of state law” were raised. Williams was serving a one-year term as president of the Board of defendant-Addison Community Schools when the Board removed him from the position. He sued the school district, the other Board members, and the then-superintendent, asserting claims under the U.S. Constitution, the Fair and Just Treatment Clause of the Michigan Constitution, and respondeat superior liability against the school district. The district court granted defendants summary judgment on all claims, and denied Williams’s motion for partial summary judgment on his state Fair and Just Treatment claim. After dismissing the federal due process claim, it “exercised supplemental jurisdiction to also dismiss Williams’s state claims.” He appealed the denial of his motion for partial summary judgment on his Michigan constitutional claim and the grant of summary judgment for defendants on that claim. The court held that exercising supplemental jurisdiction here was not a proper exercise of discretion given that “most of the circumstances contemplated by § 1367(c)” were present. The dismissal of the federal claims before trial, along with the “novelty and complexity of the remaining state claims strongly supported declining the exercise of supplemental jurisdiction in this case.” Michigan case law on the Clause is limited, and the Michigan Supreme Court has yet to address the issue of “the meaning of legislative or executive as used in” it. The court noted that “even where a § 1367(c) circumstance applies, a district court does not necessarily abuse its discretion by exercising supplemental jurisdiction; in evaluating whether to do so, [it] should still consider and weigh judicial economy, convenience, fairness, and comity.” Its holding here was “narrowly tailored given the specific factual circumstances of this case.” It vacated and remanded “with instructions for the district court to dismiss without prejudice Williams’s Fair and Just Treatment claim and related assertion of respondeat superior liability.”