Ameritox, Ltd. v. Millennium Labs., No. 14-14281 (11th Cir. 2015)
Annotate this CaseAmeritox and Millennium are competitors in the drug-testing industry. Ameritox filed suit against Millennium, alleging in its original complaint that Millennium had “formed a business plan to increase its market share, revenue, and profits” by providing financial inducements and other kickbacks, in violation of both federal and state law. The jury subsequently awarded judgment in favor of Ameritox and the district court denied Millennium’s renewed motion for judgment as a matter of law and granted in part and denied in part its motion for a new trial or reduction in the award of punitive damages; upon reconsideration, the district court reduced the award of punitive damages. In this appeal, the court concluded that the district court's decision to retain supplemental jurisdiction over novel and complex state-law claims hailing from nine different states - claims that the parties either did know or should have known were novel and complex - constituted an abuse of discretion.. Accordingly, the court vacated and remanded with instructions to dismiss the state law claims without prejudice so the parties can litigate their claims in a proper forum.
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