Layman v. City of Peoria

Citation: 352 F. Supp. 3d 874Docket: Case No. 1:18-cv-1269

Court: District Court, C.D. Illinois; November 7, 2018; Federal District Court

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The Court is assessing whether to hear Plaintiff Jeremy Layman's request for a declaratory judgment after he was terminated from the Peoria Police Department, allegedly due to statements made on social media, which he claims are protected by the First Amendment. The Court previously rejected the Defendant's Motion to Dismiss for Lack of Jurisdiction but noted concerns regarding ongoing arbitration proceedings. Although these proceedings do not make the lawsuit unripe, the Court has requested further briefing on the appropriateness of its jurisdiction.

The Plaintiff is seeking relief under the Declaratory Judgment Act, which grants federal courts broad discretion in determining whether to declare litigants' rights. The Court is evaluating whether proceeding with the declaratory judgment would be beneficial or merely a waste of judicial resources, particularly given that the arbitration process was agreed upon and mandated under Illinois law.

Key considerations include whether the purposes of the Declaratory Judgment Act would be fulfilled, the implications for federalism and comity, and factors previously outlined by the Seventh Circuit. The history behind the Act highlights its intended purpose to provide timely resolution and prevent undue hardship in disputes, especially when traditional legal remedies may be inadequate. The Court's decision will hinge on these considerations, as well as the recognition that if the Plaintiff had pursued a traditional coercive action, jurisdiction would have been clear.

The Declaratory Judgment Act aims to facilitate the early resolution of disputes and alleviate the threat of impending litigation for potential defendants. However, in the current case, these objectives are not applicable as the Plaintiff controls the litigation pace and is not deterred by coercive remedies, seeking reinstatement through labor arbitration instead. Traditional remedies suffice, and if harm has already occurred, a declaratory judgment is inappropriate. The Plaintiff claims ongoing damages, but it is unclear how a declaration would mitigate any current harm. Furthermore, there is ambiguity regarding whether the statements leading to the Plaintiff's termination were the sole reason for his dismissal, suggesting that arbitration will still be necessary regardless of the declaratory judgment. With an arbitration hearing scheduled for January 23, 2019, there is no assurance that a court decision would precede it. The Court notes that while it may exercise discretion in declaring matters, it must also consider whether a parallel litigation approach is more effective, especially in cases where only declaratory relief is sought amidst ongoing state proceedings.

The case diverges from typical scenarios involving diversity jurisdiction, as it raises questions of federal law rather than state law. A central issue is the applicability of Wilton abstention in cases involving federal questions. The Court indicates that the request for a declaration of federal law by the Plaintiff does not determine the case's trajectory towards federal court. The doctrine of comity suggests that federal courts should defer to state courts, particularly when a parallel state court action is pending, to avoid unnecessary interference. This principle holds even when federal law is implicated, as federal courts owe deference to state courts to maintain comity. 

The Court also discusses whether the ongoing arbitration can be considered a parallel state proceeding under Wilton. While declaratory relief cannot replace an arbitrator's role in contract interpretation, the Plaintiff's request seems to challenge the arbitrator's role concerning the U.S. Constitution incorporated into the contract. Although there is precedent for assuming that a pending state arbitration might qualify as a parallel action, this particular arbitration does not qualify as it is not filed in state court. However, it does involve the same issues and parties, which raises questions about its standing under Wilton. The Illinois statutory framework supports arbitration as a primary method for resolving disputes in public employment contexts, requiring exhaustion of arbitration remedies before litigation can proceed.

The collective bargaining agreement in question prevents the termination of officers for engaging in protected speech. Illinois law requires that claims related to this agreement first go through arbitration before being heard in court. The Court views arbitration as a parallel proceeding, emphasizing that a declaratory judgment would disrupt the established statutory framework for resolving disputes over personal injury protection insurance benefits. Consequently, the Court opts not to intervene at this stage.

Even if arbitration is not seen as a parallel state proceeding, the Court retains discretion to decline the case. The Court references various factors adopted by the Seventh Circuit to determine jurisdiction, including whether a judgment would settle the controversy, clarify legal relations, avoid procedural fencing, maintain state-federal harmony, and if a better alternative remedy exists. These factors yield mixed results regarding whether to proceed with the declaration. While the first factor is inconclusive and the second supports hearing the case, procedural fencing is evident as the Plaintiff prefers judicial resolution over arbitration. The fourth factor suggests caution, as the Court would be intruding into state arbitration processes. However, since the Plaintiff can still pursue a First Amendment claim in federal court, the Court concludes that issuing a declaration would not excessively intrude on state jurisdiction.

Issuing a declaration in this case may not necessarily heighten tensions between state and federal courts. The more effective remedy for the Plaintiff is to pursue arbitration, which would allow for all claims to be addressed in a single proceeding and provide coercive relief for already suffered harm. A coercive suit in federal court would also be more effective than a declaratory judgment, as it could fully remedy the Plaintiff's harm without involving the complexities of state arbitration and labor grievances. Consequently, the Court identifies two preferable options for the Plaintiff: awaiting state arbitration or filing a coercive suit in federal court.

The Court concludes that granting declaratory relief would not fulfill the objectives of the Declaratory Judgment Act and could disrupt the state law framework. Given that labor arbitration is seen as a parallel state proceeding, the Court opts not to hear the case while arbitration is ongoing. Under the Wilton standard, the Court may dismiss the case or stay the proceedings, with dismissal deemed appropriate here. Should the Plaintiff pursue claims post-arbitration, they would either be in federal court—rendering a declaratory judgment redundant—or in state court, where a federal declaratory judgment might conflict with state comity.

The Plaintiff's request for Declaratory Judgment is therefore denied, and the case is dismissed with prejudice. The case remains in the motion to dismiss phase, with the Court assuming the truth of the Plaintiff's allegations at this stage. The Court acknowledges that subsequent Plaintiff briefs may introduce consistent new facts, and notes that while the term "abstention" is not strictly accurate in this context, it will be used to describe the decision to refrain from exercising jurisdiction due to concerns over the appropriateness of hearing the case.

Under 28 U.S.C. § 1334(c)(1), a district court may abstain from hearing a proceeding related to title 11 in the interests of justice, comity with state courts, or respect for state law. This abstention differs from judicially created forms and follows the distinction noted by the Seventh Circuit in Medical Assurance Co. Such situations are rare because parties generally have the option to litigate federal questions in federal court. A plaintiff can initiate an action involving federal law in federal court (28 U.S.C. § 1331), and defendants can remove cases from state to federal court (28 U.S.C. § 1441). Declaratory judgment actions require jurisdictional statutes, making it unusual for a state court case involving a federal question to exist that cannot be removed, yet still allow district court jurisdiction over a declaratory judgment action. The District of Arizona noted in United Artists Theatre Circuit that it found a lack of subject matter jurisdiction and considered abstention only if the Ninth Circuit disagreed with this conclusion.