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Combs v. Homer-Center Sch. Dist. - 540 F.3d 231 (3d Cir. 2008)


Under 28 U.S.C.S. § 1367(c), district courts may decline to exercise supplemental jurisdiction over a state law claim if the claim raises a novel or complex issue of state law or the district court has dismissed all claims over which it has original jurisdiction. Section 1367(c) provides courts the discretion to refuse to exercise supplemental jurisdiction when values of judicial economy, convenience, fairness, and comity counsel that the district court remand state claims to a state forum.


Plaintiffs Darrell and Kathleen Combs and other parents (Parents) who home-schooled their children filed lawsuits in federal district courts against defendants Horner-Center School District and other school districts ("Districts"), challenging the reporting and review requirements under 24 Pa. Stat. Ann. § 13-1327.1 for home education programs. The Parents held in common a religious belief that "education of their children, not merely the religious education, is religion" and that God assigned religious matters to the exclusive jurisdiction of the family. Accordingly, because God gave parents the sole responsibility for educating their children, the school districts' reporting requirements and "discretionary review" over their home education programs violated their free exercise of religion. The lawsuits alleged claims under 42 U.S.C.S. § 1983 for alleged First and Fourteenth Amendment violations and under the Pennsylvania Religious Freedom Protection Act (RFPA), 71 Pa. Stat. Ann. §§ 2401-2407. The cases were consolidated in the United States District Court for the Western District of Pennsylvania, which granted summary judgment in favor of the Districts. The Parents appealed.


Did the district court err in granting summary judgment in favor of the Districts on the parents' claims?


Yes and No.


The district court's grant of summary judgment in favor of the Districts on the Parents' federal constitutional claims was affirmed. The court of appeals held that § 13-1327.1 was a neutral law of general applicability. Section 13-1327.1 survived rational basis review, as Pennsylvania had a legitimate interest in ensuring that home-schooled children achieved minimum educational standards. Faced with a split among circuits as to whether a "hybrid-rights" exception existed that would require strict scrutiny review for laws that burdened another fundamental right in addition to the free exercise right, the court of appeals held that the hybrid-rights theory was dicta  from the Supreme Court of the United States. Even if the theory were viable, the Parents did not present an independent or colorable due process claim. Because Pennsylvania courts had not construed the portion of the definition of "substantially burden" under 71 Pa. Stat. Ann. § 2403 of the RFPA upon which the Parents relied, it was appropriate to decline supplemental jurisdiction under 28 U.S.C.S. § 1367(c). Thus, the summary judgment decision in the Districts' favor on the RFPA claim was vacated, and the case was remanded to the district court with instructions to remand the RFPA claim to state court.

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