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 School Board by a procedure that he considered to be (in relevant part) a violation of federal due process and a violation of the Michigan Constitution. The state constitution specifically includes a right of Fair and Just Treatment which provides that “[t]he right of all individuals, firms, corporations and voluntary associations to fair and just treatment in the course of legislative and executive investigations and hearings shall not be infringed.”
The plaintiff sued under the federal and state constitutions. The district court granted summary judgment on the federal claim. It then “exercised supplemental jurisdiction to also dismiss Williams’s state claims.” The plaintiff then appealed only the Fair and Just Treatment claim.
The Sixth Circuit vacates and remands the summary judgment with directions that the case be dismissed without prejudice.
“This case comes to us in a relatively rare procedural posture. The district court dismissed all of Williams’s claims—both federal and state—on the merits. To do so, the court exercised supplemental jurisdiction over Williams’s state law claims after disposing of the federal claims. Williams has chosen to appeal only the district court’s disposition of a single state law claim, arising under Michigan’s constitution . . . . [A]lthough the parties contest the merits of the district court’s decision, we consider whether the exercise of supplemental jurisdiction is appropriate under the circumstances of this case. And we conclude that it is not.”
The supplemental jurisdiction statute provides, at 28 U.S.C. § 1367(c), four situations where a district court may decline to exercise supplemental jurisdiction. These include where “the claim raises a novel or complex issue of State law” and where “the district court has dismissed all claims over which it has original jurisdiction.” The latter scenario applied to this case. The panel primarily addressed itself to the novelty issue.
“Williams’s Fair and Just Treatment claim and related theory of respondeat superior liability raise novel or complex issues of state law . . . . Few Michigan cases analyze this clause, and the most extensive discussion of the provision appears in an unpublished Michigan Court of Appeals decision. Indeed, the parties acknowledge the limited case law addressing the Fair and Just Treatment clause. And Williams specifically requested that the case be heard because it raises unresolved issues of state law.” Indeed, according to the opinion, “Michigan has not yet spoken to the question of whether a private right of action exists for claims brought under the Fair and Just Treatment clause of the Michigan constitution.” The panel also notes that the Fair and Just Treatment clause has no referent in the federal constitution.
“[I]t seems axiomatic that construing a unique provision of Michigan’s constitution would qualify as sufficiently complex to warrant restraint in employing supplemental jurisdiction . . . . [C]oncerns around federal-state comity counsel that we abstain from needlessly intruding into significant state matters, such as the interpretation in the first instance of unique provisions of the state’s constitution.”
“Again, the circumstances of this case are relatively rare; in the run-of-mine case, state claims that remain after all federal claims have been resolved will involve questions that are neither novel nor complex. And even less frequently will they involve novel and complex questions arising from a state’s constitution. But because this case presents just such a rarely occurring circumstance, it was not a proper exercise of discretion to take on Williams’s Michigan Fair and Just Treatment claim and related theory of respondeat superior liability.”
Finally, the panel notes that “our holding here is narrowly tailored given the specific factual circumstances of this case.”
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