Scott Williams, a former president of the Addison Community School Board, was removed from his position following a dispute with district staff and a subsequent investigation by fellow board members. Williams sued the school district and individual board members, alleging violations of due process under the U.S. and Michigan Constitutions, as well as state constitutional torts under the Free Speech and Fair and Just Treatment clauses of the Michigan Constitution. The district court dismissed all federal claims and then exercised supplemental jurisdiction to dismiss the remaining state law claims on the merits. Williams appealed, challenging the dismissal of his Fair and Just Treatment claim specifically.
Circuit Judge Davis, writing for the panel, focused on the propriety of the district court's exercise of supplemental jurisdiction under 28 U.S.C. § 1367. The court noted that while the district court had the statutory authority to hear the state claims because they arose from the same case or controversy, it had discretion to decline jurisdiction under § 1367(c). The Sixth Circuit identified three primary factors weighing against the exercise of jurisdiction: first, the claim raised novel and complex issues of state law because the Michigan Constitution's Fair and Just Treatment clause has rarely been analyzed and lacks a federal analogue; second, the district court had already dismissed all federal claims over which it had original jurisdiction; and third, exceptional circumstances existed regarding federal-state comity. The court reasoned that interpreting a unique state constitutional provision without a federal counterpart should be left to state courts to avoid needlessly deciding state law issues. The court cited precedents like Kowall v. Benson and Brown v. Cassens Transp. Co., which established that when federal claims are dismissed and state claims involve novel constitutional questions, the balance of considerations points toward declining jurisdiction.
The decision does not resolve whether the Fair and Just Treatment clause of the Michigan Constitution creates a private right of action or what standards apply to such claims. Instead, it mandates that the district court dismiss Williams's state claim without prejudice. This allows Williams to potentially refile the claim in Michigan state court, where the state judiciary can authoritatively interpret the clause. The ruling reinforces the principle that federal courts should generally abstain from deciding novel state constitutional questions once federal claims are resolved.
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