Elmore v. Harbor Freight Tools USA, Inc., No. 16-1280 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit, alleging claims under 42 U.S.C. 1981 and state law negligence, against Harbor Freight after a Harbor Freight manager accused plaintiff of stealing from the store earlier in the day. The district court dismissed the section 1981 claim for failure to plead a state action, and declined supplemental jurisdiction on the state law claim. The court concluded that the district court did not err in dismissing the section 1981 claim because the court was bound by Youngblood v. Hy-Vee Food Stores, Inc.'s state action requirement and defendant did not plead state action in the complaint. Furthermore, the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over defendant's state law claims once the district court dismissed the claim over which it had original jurisdiction.
Court Description: Riley, Author, with Wollman and Kelly, Circuit Judges] Civil case - Civil rights. In order to state a claim under the Full-and-Equal Benefit clause of 42 U.S.C. Sec. 1981, a plaintiff must allege some sort of state action contributed to the plaintiff being discriminated against, and the district court properly dismissed plaintiff's claim as it did not plead any state action; the district court did not abuse its discretion by refusing to exercise supplemental jurisdiction over plaintiff's state law claims. [ December 22, 2016
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