Jacobs Manufacturing Co.

United States District Court for the District of Connecticut · 1990 · Labor Law

Labor LawERISApendent jurisdictionjury trialERISA Section 510pendent jurisdictionsupplemental state claimnegligent misrepresentation

Facts

The plaintiff was hired by the defendant in April 1988 and was later diagnosed with a kidney tumor in May 1989. After informing the defendant that he needed a medically related leave, he alleges that company representatives repeatedly assured him that he could take the time he needed to recover and that his position was secure. He returned to work on September 12, 1989 after being approved by the defendant's physician and was again told his position was secure, but he was terminated on September 27, 1989. He then sued, alleging that the termination was intended to interfere with his continued health benefits under the employee benefit plan and that the repeated assurances amounted to negligent misrepresentation.

Issue

Whether the court should exercise pendent jurisdiction over the plaintiff's state-law negligent misrepresentation claim appended to his ERISA § 510 claim, and whether the plaintiff is entitled to a jury trial on his ERISA § 510 claim seeking back pay and lost benefits. The case also asks whether the combination of legal and equitable relief defeats the jury demand.

Rule

Pendent jurisdiction is proper where there is a substantial federal claim, the federal and state claims derive from a common nucleus of operative fact, and the claims are such that a plaintiff would ordinarily be expected to try them in one judicial proceeding. Under the Seventh Amendment, whether a jury trial is available depends on the nature of the issues involved and the remedy sought; an ERISA § 510 action analogous to wrongful termination or breach of contract and seeking compensatory damages such as back pay and health benefits is legal in nature for those damages claims.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Elena Ruiz worked for Pine Harbor Instruments, a fictional manufacturer in Hartford, Connecticut. After she requested leave for a serious medical condition, supervisors allegedly assured her that her job would remain open, but she was fired shortly after returning and sued under ERISA § 510 for interference with benefits and under Connecticut law for negligent misrepresentation based on those assurances.

If Pine Harbor Instruments moves to dismiss the state claim for lack of pendent jurisdiction, how should the federal court most likely rule?

Explanation. Pendent jurisdiction is proper when there is a substantial federal claim and the state and federal claims derive from a common nucleus of operative fact such that they would ordinarily be tried in one proceeding. Here, both claims center on the same events surrounding the firing and alleged assurances. The case rejects the idea that differing elements alone defeat pendent jurisdiction. (Derived from Jacobs Manufacturing Co. (n.d.).)