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Hannon-Johnson v. Kansas City Area Transportation Authority

United States District Court, W.D. Missouri, Western Division

May 31, 2017




         This case arises from Plaintiff Felicia Hannon-Johnson's (“Plaintiff”) allegation that her employer, Defendant Kansas City Area Transportation Authority (“KCATA”), discriminated against her on the basis of a disability, in violation of the Missouri Human Rights Act (“MHRA”), Mo. Rev. Stat. § 213.010, et seq. Plaintiff originally brought suit in the Circuit Court of Jackson County, Missouri, and KCATA removed the lawsuit to federal court, invoking the Court's federal question jurisdiction.

         Now before the Court is Plaintiff's Motion to Remand (Doc. 33). For the reasons set forth below, Plaintiff's motion is GRANTED.


         Defendant KCATA is a bi-state public transit entity operating in the Kansas City metropolitan area. It was created in 1965 pursuant to a Congressionally-approved compact between Missouri and Kansas (the “Compact”).[1] See Act of Sept. 21, 1966, Pub. L. 89-599, 80 Stat. 826 (consenting to KCATA compact); Kan. Stat. Ann. § 12-2524, art. III; Mo. Rev. Stat. § 238.010, art. III. The Compact grants KCATA certain enumerated powers, along with the authority “[t]o perform all other necessary and incidental functions [not enumerated in the Compact]; and to exercise such additional powers as shall be conferred on it by the Legislature of either State concurred in by the Legislature of the other and by Act of Congress.” Kan. Stat. Ann. § 12-2524, art. III, § 11; Mo. Rev. Stat. § 238.010, art. III, § 11.

         From April 2005 to March 2016, KCATA employed Plaintiff as a bus driver and customer service representative. Am. Compl. ¶¶ 12-14, 42. Plaintiff was terminated in March 2016. Plaintiff now alleges KCATA violated the MHRA by failing to provide her with reasonable accommodations for a back, leg, ankle, and foot disability stemming from an on-the-job accident. See, e.g., id. ¶¶ 15-16, 18-21, 28, 30-32. She also asserts her termination was in retaliation for filing charges of discrimination against KCATA. See, e.g., id. ¶¶ 34-43.

         Plaintiff originally filed this lawsuit in Missouri state court. On November 11, 2016, KCATA removed this matter to federal court.


         An action may be removed by the defendant where the case falls within the district court's original jurisdiction. 28 U.S.C. § 1441(a). If the case does not fall within these jurisdictional bounds, the district court must remand the case to the state court from which it was removed. Id. § 1447(c). The removing party has the burden of establishing jurisdiction by a preponderance of the evidence, Hartis v. Chicago Title Ins. Co., 656 F.3d 778, 781-82 (8th Cir. 2009), and any doubts about the propriety of removal are to be resolved in favor of remand. Central Iowa Power Indep. Transmission Sys. Operator, Inc., 561 F.3d 904, 912 (8th Cir. 2009).

         A district court has “original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. To determine whether the action arises under federal law, a court employs the “well-pleaded complaint” rule, which “provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint.” Caterpillar, Inc. v. Williams, 482 U.S. 386, 392 (1987). But, an exception to this rule exists where “the plaintiff's right to relief necessarily depends on resolution of a substantial question of federal law.” Great Lakes Gas Transmission Ltd. P'ship v. Essar Steel Minn. LLC, 843 F.3d 325, 329 (8th Cir. 2016) (quoting Williams v. Ragnone, 147 F.3d 700, 702 (8th Cir. 1998)). When determining whether this exception applies, a court must ask, “[D]oes [the] state-law claim necessarily raise a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities[?]” Grable Sons Metal Prods., Inc. v. Darue Eng'g Mfg., 545 U.S. 308, 314 (2005). “That is, federal jurisdiction over a state law claim will lie if a federal issue is: (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution in federal court without disrupting the federal-state balance approved by Congress.” Gunn v. Minton, 133 S.Ct. 1059, 1065 (2013).


         KCATA contends federal jurisdiction exists because Plaintiff's claims necessitate interpretation of the Compact, which became federal law after it was approved by Congress. It argues that, under the Compact, KCATA cannot be subject to Missouri's employment discrimination laws. Plaintiff did not file a reply brief or otherwise respond to this argument.

         I. Construction of the Compact presents a federal question.

         As an initial matter, there is no dispute that the construction of the Compact presents a federal question. See Cuyler v. Adams, 449 U.S. 433, 438 (1981) (“Because congressional consent transforms an interstate compact [within the Compact Clause] into a law of the United States, we have held that the construction of an interstate agreement sanctioned by Congress . . . presents a federal question.”). But, the “mere presence of a federal issue in a state cause of action does not automatically confer federal jurisdiction.” Merrell Dow Pharms. Inc. v. Thompson, 478 U.S. 804, 813 (1986). Accordingly, the Court must perform a Grable inquiry to determine the “centrality” of the federal issue and, ultimately, its jurisdiction over this matter. See Empire ...

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