Background
Julie A. Meckfessel Poletti, proceeding without counsel, filed suit against Workday, Inc. in Sacramento County Superior Court. The original complaint alleged federal employment-law violations under the Americans with Disabilities Act, the Genetic Information Nondiscrimination Act, the Age Discrimination in Employment Act, and Title VII, and Workday removed the action to the U.S. District Court for the Eastern District of California on June 8, 2026 based on federal question jurisdiction. Poletti had previously sued Workday in a related Eastern District action, Meckfessel-Poletti v. Workday, Inc., No. 2:25-cv-01315-DJC-CSK (PS), which the district judge dismissed without leave to amend on February 20, 2026.
On July 6, 2026, Poletti filed a First Amended Complaint that deleted the federal claims and pleaded only state-law causes of action: three California Fair Employment and Housing Act claims for employment discrimination, harassment, and retaliation; a Bane Act claim under California Civil Code § 52.1; a California Labor Code § 1102.5 claim; an Unruh Civil Rights Act claim under California Civil Code § 51; and intentional infliction of emotional distress. Workday then moved to dismiss the amended complaint, arguing that the claims were time-barred, barred by res judicata because of the earlier Meckfessel I dismissal, that Workday was never Poletti's employer, and that the Unruh Act and Bane Act allegations failed on the merits. Workday also asked the court to take judicial notice of sixteen court and agency records, which the magistrate judge granted.
The magistrate judge submitted the motion on the record under Local Rule 230(g) after vacating the September 1, 2026 hearing. The resulting Findings and Recommendations, dated October 27, 2026 and filed October 28, 2026 in Case No. 2:26-cv-02105-DJC-CSK (PS), are addressed to the assigned district judge under 28 U.S.C. § 636(b)(1) and are not themselves a final remand order.
The Court’s Holding
The magistrate judge concluded that the court lacks subject matter jurisdiction over the removed action. Under the Supreme Court's 2025 decision in Royal Canin U.S.A., Inc. v. Wullschleger, when a plaintiff amends a complaint after removal and eliminates the federal-law claims that supported removal, leaving only state-law claims, the federal court's power to decide the dispute dissolves. The amended complaint supersedes the original complaint, so the court cannot rely on the original federal claims to preserve jurisdiction.
Because Poletti's First Amended Complaint contains exclusively state-law claims and because both parties appear to be citizens of California, leaving no apparent diversity jurisdiction, the magistrate judge concluded that the court lacks supplemental jurisdiction to hear the state-law claims. The court therefore recommended sua sponte remanding the action to Sacramento County Superior Court. In light of that recommended remand, the magistrate judge also recommended denying Workday's motion to dismiss as moot, because a court without jurisdiction cannot reach the merits of the state-law claims or the dismissal defenses.
The recommendation has three operative parts: remand the matter to Sacramento County Superior Court; deny Workday's motion to dismiss the First Amended Complaint as moot; and direct the Clerk of the Court to close the case. The document expressly states that these are findings and recommendations submitted to the district judge, with written objections permitted within fourteen days, so the remand and denial are recommendations rather than final orders. The state-law merits issues raised in Workday's motion—including limitations, res judicata, employer status, and the Unruh and Bane Act allegations—are left undecided.
Key Takeaways
- When a plaintiff amends a complaint after removal to eliminate all federal claims, the operative amended pleading controls and federal question jurisdiction dissolves under Royal Canin U.S.A., Inc. v. Wullschleger.
- Federal courts must consider subject matter jurisdiction sua sponte, and a court that lacks jurisdiction cannot decide the merits or deny a motion to dismiss on the merits.
- A magistrate judge's findings and recommendations are not final orders; the assigned district judge must act on them, and parties may file objections within fourteen days.
- When remand for lack of jurisdiction is recommended, pending dismissal arguments become moot and the state-law claims remain for the state court to resolve.
- Granting judicial notice of public court records does not create jurisdiction; it only permits the court to consider undisputed record facts.
Why It Matters
The recommendation applies Royal Canin's rule that a post-removal amended complaint supersedes the original pleading for jurisdictional purposes, confirming that abandoned federal claims cannot keep a removed case in federal court. It also illustrates the practical consequence of a jurisdictional defect: instead of adjudicating Workday's statute-of-limitations, res judicata, employer-status, or state-statutory defenses, the magistrate judge recommended returning the entire dispute to state court and treating the federal motion to dismiss as moot.
Procedurally, the document underscores the difference between a magistrate judge's advisory findings and a final district-court order. Because the recommendation is submitted under 28 U.S.C. § 636(b)(1), the remand, mootness denial, and closure directive remain subject to district-judge action and any timely objections.
Read the full opinion (PDF) · Court docket