On November 7, 2016, the U.S. District Court for the Southern District of Florida sua sponte declined to exercise supplemental jurisdiction over, and dismissed, a TCPA plaintiff’s two state law claims. The plaintiff has alleged that Residential Credit Solutions, Inc. placed hundreds of debt collection calls to his mobile phone using an autodialer, in violation of the TCPA, as well as the Florida Consumer Collection Practices Act (FCCPA), which prohibits abusive or harassing conduct in attempt to collect a debt. The court has supplemental jurisdiction over the FCCPA claims, the plaintiff argued, because such claims are “so related to the federal TCPA claim that they form part of the same case or controversy under Article III.” Travis v. Residential Credit Solutions, Inc., No. 0:16-cv-62552 (S.D. Fla.).
The court determined that it clearly has original jurisdiction over the TCPA claim, and found that it has supplemental jurisdiction over the asserted FCCPA claims, as they “are so related to the federal claim... that [they each] form part of the same case or controversy.” The court ultimately concluded, however, that it should not exercise jurisdiction over the state law claims because they present novel and complex questions of state law that would otherwise predominate over the TCPA claim, obscuring its significance. As a result, the court dismissed the two state law claims, but not before warning against the “current trends in the law favor[ing] expanded federal court jurisdiction.”