Brown v. FCA US LLC ( 2022 )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CHRISTOPHER BROWN, Plaintiff, No. 22-10626 v. Hon. Nancy G. Edmunds FCA US LLC, Defendant. _______________________________________/ ORDER DISMISSING PLAINTIFF’S STATE LAW CLAIMS Plaintiff Christopher Brown brings this employment discrimination lawsuit against Defendant FCA US LLC. He alleges violations of the Americans with Disabilities Act, Michigan Persons with Disabilities Civil Rights Act, Age Discrimination in Employment Act (“ADEA”), and Michigan Elliot-Larsen Civil Rights Act (“ELCRA”). Because the parties in this case are nondiverse, the Court declines to exercise supplemental jurisdiction over Plaintiff’s state law claims so as to avoid jury confusion. See 28 U.S.C. § 1367(c)(4); Moor v. Cty. of Alameda, 411 U.S. 693, 716 (1973); Padilla v. City of Saginaw, 867 F. Supp. 1309, 1315 (E.D. Mich. 1994); see also Provenzano v. LCI Holdings, Inc., 663 F.3d 806, 818 (6th Cir. 2011) (observing that the causation standard for a discrimination claim under the ADEA is different than that for the same claim under the ELCRA). Therefore, pursuant to § 1367(c), Plaintiff's state law claims are hereby DISMISSED WITHOUT PREJUDICE. The Court will retain jurisdiction over Plaintiff’s federal claims only. 1 SO ORDERED. s/Nancy G. Edmunds Nancy G. Edmunds United States District Judge Dated: April 4, 2022 I hereby certify that a copy of the foregoing document was served upon counsel of record on April 4, 2022, by electronic and/or ordinary mail. s/Lisa Bartlett Case Manager 2