United States District Court, N.D. Illinois, Eastern Division
MEMORANDUM OPINION AND ORDER
M. DURKIN UNITED STATES DISTRICT JUDGE.
Sharun M. Coleman (“Coleman”) has asked this
Court to reconsider Judge Darrah's February 15, 2007
Memorandum Opinion and Order dismissing her state law
petition for writ of mandamus, finding “no basis for
federal subject matter jurisdiction over plaintiff's
state law claim for mandamus.” R. 54 at 4. For the
reasons set forth below, the Court grants Coleman's
Motion to Reconsider based on an error in application of law.
Court has “inherent authority” under Rule 54(b)
to reconsider its interlocutory orders. Janusz v. City of
Chi., 78 F.Supp.3d 782, 787 (N.D. Ill. 2015);
Fed.R.Civ.P. 54(b) (Non-final orders “may be revised at
any time before entry of a judgment adjudicating all the
claims and all the parties' rights and
liabilities.”). A motion to reconsider is not, however,
a proper vehicle for rehashing arguments that the Court
previously rejected. See Janusz, 78 F.Supp.3d at
787. “Rather, a motion to reconsider allows a party to
direct the court's attention to manifest errors of fact
or law, a significant change in the law or facts, the
court's misunderstanding of a party's argument, or a
party's contention that the court ruled on an issue that
was not properly before it.” Id.
Sharun M. Coleman is an African-American resident of the
Northern District of Illinois. R. 18 ¶ 3. In 2014,
Coleman applied for employment as a correctional officer with
the Cook County Sheriff. Id. ¶ 7. Before an
applicant can be employed as a correctional officer, Illinois
law requires that he or she be certified by the Merit Board,
an entity created by Illinois law, as being qualified for
such employment. 55 ILCS 5/3-7002; R. 18 ¶ 8. At the
time Coleman applied for employment, she met all of the
qualifications required for certification by the Merit Board.
Id. ¶ 9. After applying for employment as a
correctional officer, Coleman successfully passed all of the
mental, physical, psychiatric, and other tests and
examinations that had been prescribed by the Merit Board.
Id. ¶ 10. However, the Merit Board did not
certify Coleman in 2015. Id. ¶ 12.
September 22, 2016, Coleman filed an amended complaint
against the Merit Board, the Sheriff of Cook County, and Cook
County. R. 18. The complaint alleges that the Sheriff of Cook
County denied plaintiff equal employment opportunities in
violation of Title VII of the Civil Rights Act due to racial
animus on the part of the Merit Board. In the alternative,
Coleman seeks a state law writ of mandamus against the Merit
Board compelling the Merit Board to certify her for
employment as a correctional officer and for other equitable
relief. R. 18 ¶¶ 17-19.
filing this lawsuit, Coleman learned that the Merit Board
refused to certify her for employment because its
investigator had stated that Coleman had withheld her
relationship with a convicted felon from the Merit Board.
Id. ¶ 15. Coleman alleges that this statement
was false, and that it was contradicted by the materials
considered by the investigator. Id. ¶ 16.
Coleman also alleges that the investigator was motivated by
racial animus or, in the alternative, was grossly negligent.
Merit Board moved for dismissal of Coleman's state law
claim. R. 28. On February 15, 2017, Judge Darrah issued a
Memorandum Opinion and Order, finding that because plaintiff
did not assert a federal claim against the Merit Board, there
was “no basis for federal subject matter jurisdiction
over plaintiff's state law claim for mandamus.” R.
55 at 4. Judge Darrah therefore dismissed Coleman's state
law writ of mandamus claim against the Merit Board.
Id. Presently before the Court is Coleman's
Motion to Reconsider Judge Darrah's Opinion dismissing
her state law mandamus claim for lack of subject matter
jurisdiction. R. 59.
argues that the Court committed manifest error of law when it
ruled that it lacked subject-matter jurisdiction over
Coleman's state law claim against the Merit Board on the
ground that plaintiff is not asserting a federal claim.
writ of mandamus claim arises under Illinois state law. The
Court does not have original jurisdiction over this state law
claim and may address it only if it chooses to exercise its
supplemental jurisdiction. “28 U.S.C. § 1367
allows a district court to decide any ‘claims'
related to other claims over which the court has original
jurisdiction ‘if they are so closely related to the
plaintiff's federal-law claims as to be in effect part of
the same case.'” Hadad v. World Fuel Services,
Inc., No 13 C 3802, 2013 WL 6498894 at *3 (Dec. 11,
2013) (quoting Williams Elecs. Games, Inc. v.
Garrity, 479 F.3d 904, 906 (7th Cir. 2007)); see
also Ammerman v. Sween, 54 F.3d 423 (7th Cir. 1995)
(“[28 U.S.C. § 1367] authorize[s] federal courts
to hear all claims that are ‘so related to claims in
the action within such original jurisdiction that they form
part of the same case or controversy.”).
form part of the same case or controversy when they
“derive from a common nucleus of operative fact.”
United Mine Workers v. Gibbs, 383 U.S. 715, 725
(1966). To meet this requirement, “[a] loose factual
connection between the claims is generally sufficient.”
Ammerman, 54 F.3d at 424. The purpose of
supplemental jurisdiction is “to promote ‘economy
in litigation, ' as it would be inefficient to adjudicate
essentially the same issues in two separate forums.”
Hadad, 2013 WL 6498894 at *3. Additionally,
“[t]he joinder of an additional party against whom the
plaintiff has a state claim closely related to the claim on
which federal ...