Novel State Constitutional Claims Require Restraint: Declining Supplemental Jurisdiction After Federal Claims Fall

1. Introduction

In Scott Williams v. Addison Cmty. Schs., the Sixth Circuit addressed not the merits of a Michigan constitutional claim, but whether a federal court should decide it at all. Scott W. Williams, an elected member—and then-president—of the Addison Community Schools Board, sued the school district, the superintendent, and several board members after the Board adopted a resolution censuring him and removing him from the presidency.

Williams asserted, among other theories, a state constitutional tort claim under Michigan’s Fair and Just Treatment clause (Mich. Const. art. I, § 17) and sought to hold the District liable via respondeat superior. The district court disposed of the federal claims and then adjudicated the state constitutional claims on the merits under supplemental jurisdiction. On appeal, Williams challenged only the Fair and Just Treatment disposition (including respondeat superior against the District), placing the Sixth Circuit in the position of reviewing whether it was appropriate for a federal court to decide an unsettled question of Michigan constitutional law.

2. Summary of the Opinion

The Sixth Circuit vacated the district court’s merits decision on the Michigan Fair and Just Treatment claim and remanded with instructions to dismiss without prejudice that claim (and the related respondeat superior theory). The court held that the district court abused its discretion by exercising supplemental jurisdiction over a claim presenting novel and complex state constitutional issues after all federal claims had been dismissed.

3. Analysis

A. Precedents Cited

The decision is a synthesis of Sixth Circuit supplemental-jurisdiction doctrine, with particular emphasis on comity where state-law questions are unsettled—especially when they arise under a state constitution.

  • Grubbs v. Sheakley Grp., Inc., 807 F.3d 785 (6th Cir. 2015)
    The court cited Grubbs for the standard of review: a district court’s decision to exercise supplemental jurisdiction is reviewed for abuse of discretion. That framing matters because the Sixth Circuit did not need to decide the underlying Michigan constitutional question to reverse; it needed only to find that discretion was misapplied.
  • Faber v. Ciox Health, LLC, 944 F.3d 593 (6th Cir. 2019)
    Faber supplied the familiar federal-courts principle that when state law is unsettled, a federal court must predict how the state’s highest court would rule. The Sixth Circuit highlighted that the district court (and the Sixth Circuit, if it reached merits) would be forced into prediction because “Michigan has not yet spoken” on whether a private right of action exists under the Fair and Just Treatment clause.
  • Blakely v. United States, 276 F.3d 853 (6th Cir. 2002)
    The panel relied on Blakely to emphasize that § 1367(c) is permissive: a district court may, not must, decline supplemental jurisdiction when one of the statutory factors applies. But permissive power does not eliminate the obligation to apply it prudently.
  • Stanley v. W. Mich. Univ., 105 F.4th 856 (6th Cir. 2024)
    Stanley reinforced two key points: (1) supplemental jurisdiction discretion is “bounded by constitutional and prudential limits,” and (2) when all federal claims are dismissed before trial, the usual balance points toward dismissing remaining state-law claims. The panel used Stanley as a modern anchor for the comity-centered approach it adopted here.
  • Gamel v. City of Cincinnati, 625 F.3d 949 (6th Cir. 2010) and Landefeld v. Marion Gen. Hosp., Inc., 994 F.2d 1178 (6th Cir. 1993)
    These cases supplied the classic balancing test: judicial economy, convenience, fairness, and comity, including the admonition (from Landefeld) against “needlessly deciding state law issues” when federal jurisdiction has dissipated.
  • Robert N. Clemens Tr. v. Morgan Stanley DW, Inc., 485 F.3d 840 (6th Cir. 2007)
    This citation served a structural role: it confirmed that § 1367(a) empowered supplemental jurisdiction because the state and federal claims arose from the same “case or controversy” (the removal of Williams as Board president).
  • Kowall v. Benson, 18 F.4th 542 (6th Cir. 2021)
    This was the most direct doctrinal predecessor. The panel quoted Kowall for the proposition that novel questions of state constitutional law are “best left for state courts to answer in the first instance,” especially after federal claims are dismissed.
  • Brown v. Cassens Transp. Co., 546 F.3d 347 (6th Cir. 2008) and Moon v. Harrison Piping Supply, 465 F.3d 719 (6th Cir. 2006)
    The panel analogized from these cases—each cautioning against retention of jurisdiction over difficult Michigan tort questions once federal claims are gone—to argue that deciding a novel Michigan constitutional tort question is, a fortiori, a poor candidate for supplemental jurisdiction.
  • Varsity Brands, Inc. v. Star Athletica, LLC, 799 F.3d 468 (6th Cir. 2015)
    Cited to confirm the negative proposition: district courts are not categorically required to dismiss state claims after federal dismissal. The Sixth Circuit treated this as a baseline rule that yields when the § 1367(c) factors and comity considerations strongly counsel restraint.
  • Hucul Advert., LLC v. Charter Twp. of Gaines, 748 F.3d 273 (6th Cir. 2014) and Veneklase v. Bridgewater Condos, L.C., 670 F.3d 705 (6th Cir. 2012)
    These cases were used to avoid overreading the opinion. The court reaffirmed that the “default assumption” is that federal courts will exercise supplemental jurisdiction over related claims, and it stressed that its holding was “narrowly tailored” to the “rare” posture presented here.
  • Shearson v. Holder, 725 F.3d 588 (6th Cir. 2013) and Lipman v. Budish, 974 F.3d 726 (6th Cir. 2020)
    These cases governed the scope of relief. Williams asked the Sixth Circuit to clarify that vacatur should extend to other state constitutional claims, but he had abandoned them on appeal. Under Shearson and Lipman, unbriefed claims are abandoned; the court therefore limited its action to the Fair and Just Treatment claim and the linked respondeat superior theory.

B. Legal Reasoning

The opinion’s core move is jurisdictional prudence: the Sixth Circuit treated the presence of an unresolved Michigan constitutional question as a powerful reason to decline supplemental jurisdiction once the federal claims had been dismissed. The court applied the statutory framework of 28 U.S.C. § 1367 in three steps:

  1. Power (§ 1367(a)): The district court had authority because the state claim formed part of the same case or controversy as the federal claims (all centered on Williams’s removal as Board president).
  2. Permission to decline (§ 1367(c)): Multiple § 1367(c) factors were present:
    • § 1367(c)(1)—the claim raised “novel or complex” issues of state law because Michigan courts have scarcely interpreted the Fair and Just Treatment clause and the Michigan Supreme Court has not addressed whether it supports a private cause of action.
    • § 1367(c)(3)—all federal claims had been dismissed.
    • § 1367(c)(4)—“exceptional circumstances” and “other compelling reasons,” rooted in comity: no federal analogue to the clause and no Michigan statutory equivalent to § 1983 to guide cause-of-action analysis.
    The court noted that § 1367(c)(2) (state claims substantially predominate) did not apply.
  3. Prudential balancing: Weighing judicial economy, convenience, fairness, and comity, the court acknowledged that efficiency could favor retaining the claim, but found that comity predominated given the “rarely occurring circumstance” of a novel state constitutional claim requiring first-instance interpretation.

The remedy follows directly from this reasoning: because the federal court should not have reached the merits, its merits judgment must be vacated, and the claim must be dismissed without prejudice so it can be pursued in Michigan courts.

C. Impact

The decision’s practical effect is to sharpen the Sixth Circuit’s guidance on when declining supplemental jurisdiction is not merely permissible but required to avoid an abuse of discretion:

  • State constitutional novelty is a red flag: After dismissal of federal claims, the presence of unsettled state constitutional questions (especially those lacking federal analogues) strongly favors dismissal without prejudice.
  • Comity can outweigh efficiency: Even where the record is developed enough to decide summary judgment, the federal court should resist becoming the first authoritative interpreter of a state constitution when state courts have not spoken.
  • Downstream litigation strategy: Plaintiffs asserting novel state constitutional torts should expect removal or retention fights to pivot on § 1367(c)(1), (3), and (4). Defendants who prefer a federal forum may have difficulty keeping such claims in federal court once the federal hooks are gone.
  • Institutional message to district courts: The opinion reaffirms broad discretion but signals that discretion has enforceable limits where federal adjudication would “needlessly” decide foundational state constitutional questions.

4. Complex Concepts Simplified

  • Supplemental jurisdiction: A federal court’s ability to hear state-law claims that are factually related to federal claims in the same lawsuit (28 U.S.C. § 1367(a)).
  • Declining supplemental jurisdiction (§ 1367(c)): Even if the court has power to hear state claims, it may choose not to when the state issues are novel/complex, when federal claims are gone, or for other compelling reasons.
  • Comity: Respect for state courts’ primary role in interpreting state law—especially a state’s constitution.
  • “Without prejudice” dismissal: The claim is not rejected on its merits; the plaintiff may refile it in the proper forum (typically state court).
  • State constitutional tort: A claim seeking damages or other relief directly for violation of a state constitutional provision. Whether such a remedy exists often depends on state-law doctrines about implied causes of action—an issue the Sixth Circuit intentionally avoided deciding here.
  • Fair and Just Treatment clause (Mich. Const. art. I, § 17): A Michigan constitutional protection for “fair and just treatment” during “legislative and executive investigations and hearings.” The opinion underscores that Michigan courts have not definitively defined key terms or recognized a private damages remedy under this clause.
  • Respondeat superior: A theory for holding an entity liable for the acts of its agents/employees. Here, Williams sought to apply it to the school district for alleged state-constitutional violations—another unsettled question tied to the underlying state constitutional tort claim.

5. Conclusion

Scott Williams v. Addison Cmty. Schs. establishes a clear Sixth Circuit caution: when federal claims are dismissed and the remaining dispute requires first-instance interpretation of a novel and complex state constitutional provision—especially one with no federal analogue—federal courts should ordinarily decline supplemental jurisdiction. By vacating the merits ruling and ordering dismissal without prejudice, the Sixth Circuit prioritized comity and the proper allocation of interpretive authority to Michigan courts, leaving Michigan’s judiciary to decide whether and how the Fair and Just Treatment clause supports a private right of action and related theories of liability.