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Sixth Circuit Reverses a District Court for Exercising Supplemental Jurisdiction and Granting Summary Judgment on a Novel Michigan State-Constitutional Claim

In Williams v. Addison Cmty. Schs., No. 25-1205 (6th Cir. Mar. 2, 2026), the Sixth Circuit issues a rare published opinion reversing a district court for exercising supplemental jurisdiction (28 U.S.C. § 1367(a)), here over a Michigan state-law claim that raised issues of first impression. Plaintiff Williams was removed as President of the Addison Community…

Fourth Circuit Holds That Stipulation of Dismissal Without Prejudice Can Be Remedied by Plaintiff Waiver in Appellate Briefing or Argument

In Metz v. McCarthy, No. 24-1820 (4th Cir. Feb. 25, 2026), the Fourth Circuit holds that a stipulation in the district court of dismissal without prejudice, which would deprive the court of appellate jurisdiction, can be repaired on appeal by the expedient of the plaintiff agreeing in briefing or argument that dismissal of all claims…

Fifth Circuit Skirts Question of Application of Fed. R. Civ. P. 17(c) to Party Suspected to Be, But Not Yet Adjudicated As, Incompetent

In Boudy v. McComb Sch. Dist., No. 24-60386 (5th Cir. Feb. 24, 2026), the Fifth Circuit avoids, though bookmarking for another time, whether it is an abuse of discretion to dismiss a case in the face of pro se party’s suspected incompetency. The plaintiff-appellant urged the court to adopt the Ninth Circuit’s rule on this…

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