In Malphurs v. Cooling Tower Systems, Inc., Amanda Malphurs worked at Cooling Tower Systems in an hourly position from November 2011 to May 2012. Her duties included working in her employer’s warehouse, posting cooling tower lines and other equipment for sale on an auction website, and doing other office work. During this time, Malphurs was allegedly denied overtime compensation for her work beyond eight hours in the day. At the same time, she was allegedly exposed to “frequent, ongoing, and continuous harassing conduct of a sexual nature” by Joe Coates, the sole owner of Cooling Tower Systems. He would require Malphurs to work long hours late into the day allegedly so they could be alone, and when Malphurs requested overtime pay, he refused to compensate her unless she acquiesced to his sexual demands.
Malphurs frequently asked Coates to stop his harassment, but Coates ignored her. As he was her sole boss, she could not turn to anyone else to discipline or terminate him. Finally, unable to cope with the situation any further, Malphurs quit.
In November 2013, she filed a lawsuit in federal against Cooling Tower Systems, Inc. and Coates, claiming violations of Georgia law as well as violations of the Fair Labor Standards Act (FLSA). Malphus argued that because the federal court had jurisdiction over her FLSA claim, the Court also had supplemental jurisdiction over her state law claims. Meanwhile, her employer argued that the case should be dismissed from federal court.
The court examined whether it had supplemental jurisdiction over Malphus’s state law claims. The issue revolved around whether the other claims “arose out of a common nucleus of operative fact with a substantial federal claim,” which would supply original jurisdiction. The court must take the nucleus of facts that the federal claim is based on and see if it also applied to the state claims.
Cooling Tower Systems, Inc. and Coates argued that the only thing Malphus’s state claims had in common with her federal claim was that she was a former employee, and that it was not enough to establish supplemental jurisdiction. However, the court noted that Malphus’s sexual harassment claim was interwoven with her overtime compensation claim — she was required to work beyond normal hours precisely so Coates could sexually harass her without other employees present, and she could not receive compensation unless she acquiesced. As such, there was more than the bare existence of an employment relationship. The court also examined whether the state law claims would predominate over federal claims, another reason for dismissal, and found that even if they did, the court could consider other factors like judicial economy, convenience, fairness to the parties, and whether all the claims would be expected to be tried together. In the end, that was enough for the court to deny the other party’s motion to dismiss.
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