Young v. City of Memphis and Memphis Police Department - Federal Claims Dismissed, State Law Remanded

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April 21, 2026 Get Citation Alerts Download PDF Add Note

Symara A.C. Young v. City of Memphis and Memphis Police Department

District Court, W.D. Tennessee

• Citations: None known
• Docket Number: 2:25-cv-02799

• Precedential Status: Unknown Status

• Opinion

• Authorities (5)

• Cited By (0)

• Summaries (0)

• Similar Cases (0)

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Trial Court Document

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION
SYMARA A.C. YOUNG, )
)
Plaintiff,
)
)
v. No. 2:25-cv-2799-SHL-atc
)

)
CITY OF MEMPHIS and MEMPHIS
)
POLICE DEPARTMENT,
)
Defendants. )
ORDER GRANTING CITY DEFENDANTS’ MOTION TO DISMISS PLAINTIFF
SYMARA A.C. YOUNG’S FEDERAL CLAIM AND REMANDING NEGLIGENCE
CLAIM TO STATE COURT
Before the Court is Defendant City of Memphis and Memphis Police Department’s (the
“City Defendants”) Motion to Dismiss Plaintiff’s Second Amended Complaint.1 After the
Motion was fully briefed, Plaintiff Symara A.C. Young filed a Motion for Leave to File a
Supplemental Memorandum in Response to City of Memphis’s Second Motion to Dismiss
Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure on April 3, 2026. (ECF No.
88.) The Court granted that motion, and Young filed her supplemental memorandum on April 5.
(ECF No. 90.)
In the motion seeking to file the supplemental response and the supplemental
memorandum, Young explained that she does not object to the dismissal of her federal claim,

1 The City Defendants filed their motion to dismiss in this case before it was consolidated
with Shonda R. White, Individually and as Mother and Next Friend of Lasundra Josephine
White, a Minor, and Jasmine Kinds, Deceased Minor v. City of Memphis, Tennessee, 25-cv-
2800-SHL-atc. The Court entered an Order dismissing the federal claims in that case and
remanding the remaining claims to state court. (ECF No. 87.) For ease of reference, the Court
relies on the ECF filings from the consolidated cases, that is 25-cv-2799, herein.
and asserts that the Court should take an approach consistent with its decision in the related
White matter, where it dismissed the federal claim and remanded the case to state court for a
determination of the state-law claim. (ECF No. 88 at PageID 612.)
The City Defendants filed a response to the supplemental memorandum on April 20,

1. (ECF No. 91.) The City Defendants’ response, like their response to the similar motion in the White matter, asserts that the Court should dismiss all of Young’s claims, including the state- law claim. According to the City Defendants, “[b]ecause Plaintiff does not oppose dismissal of her federal claims and fails to demonstrate she has a viable state law claim under the [Tennessee Governmental Torts Liability Act], the Court should dismiss both claims with prejudice.” (ECF No. 91 at PageID 640.) There is distinction between the position the City Defendants took in White versus the position it has taken in this case, however. In White, the City Defendants explained that they did “not oppose the Court exercising its discretion pursuant to 28 U.S.C. § 1367 (c)(3) to either continue exercising supplemental jurisdiction over a remaining state law claim or remanding the

matter to the state court as Plaintiff requests” (ECF No. 86 at PageID 604), while acknowledging
that “the typical practice among federal courts in the Sixth Circuit in similar circumstances is to
remand the case to state court to resolve remaining issues of state law” (id. (citing Devereux v.
Knox Cnty., 15 F.4th 388, 396 (6th Cir. 2021))). Here, however, the City makes no such
concession, acknowledging that, although it is usually best in such circumstances to allow the
state courts to decide state issues, “there is a strong interest in promoting judicial economy by
dismissing Plaintiff’s state law claims” here rather than remanding them to the state court for
adjudication. (ECF No. 91 at PageID 645.) The City Defendants assert that “remanding
Plaintiff’s state law claims will force them to re-litigate arguments which they have fully briefed
in the present action,” and that the state law claims do not present complex issues of law. (Id.)
“[O]verwhelming interests in judicial economy may allow a district court to properly
exercise its discretion and decide a pendent state claim even if the federal claim has been

dismissed before trial.” Aschinger v. Columbus Showcase Co., 934 F.2d 1402, 1412 (6th Cir.
1991) (citing Province v. Cleveland Press Publ’g Co., 787 F.2d 1047, 1054 (6th Cir. 1986)). “In
determining whether to retain jurisdiction over state-law claims, a district court should consider
and weigh several factors, including the ‘values of judicial economy, convenience, fairness, and
comity.’” Gamel v. City of Cincinnati, 625 F.3d 949, 951–52 (6th Cir. 2010) (quoting Carnegie–
Mellon Univ. v. Cohill, 484 U.S. 343, 350 (1988)). A court may consider additional factors,
including “the avoidance of multiplicity of litigation,” as well as “whether the plaintiff has
engaged in any manipulative tactics when it decides whether to remand a case.” Id. (citations
omitted).
Here, the Court GRANTS the City’s motion to dismiss Young’s federal claims based on

her lack of opposition. This leaves the only question whether the Court will exercise jurisdiction
over the state law TGTLA claim. Each of the relevant factors weighs in favor of remanding the
case the state court. It will be more convenient to have what is left of this matter—and what was
originally at issue before a federal claim was added and the matter was removed—heard in state
court. That is where the case began, where the bulk of the litigation in the case has taken place,
and where the White matter, the case that this case was previously consolidated with both here
and in state court, was recently remanded. There are no overwhelming interests in judicial
economy that recommend that the Court retain jurisdiction over the state law claim, as the parties
can focus any future motion practice on the narrow set of issues that will be pending before the
state court. Moreover, remanding this case to the state court will not only serve to avoid the
multiplicity of litigation, as the White matter involves the same incident that gives rise to the
claims in this matter, but it will also help avoid the risk of conflicting resolutions for similar legal
issues, all of which deal with the application of state law. In short, judicial economy,

convenience, fairness, and comity all weigh in favor of remand, and the Court assumes that the
case will once again be consolidated in state court with the White matter, which also will avoid
the multiplicity of litigation. Accordingly, the factors weigh in favor of following the typical
practice among federal courts in the Sixth Circuit, and remanding the case to state court to
resolve remaining issues of state law.
For the foregoing reasons, the Court also finds it appropriate to dismiss Young’s 28
U.S.C. § 1983 claim, and to remand her remaining claim to state court.
IT IS SO ORDERED, this 21st day of April, 2026.
s/ Sheryl H. Lipman
SHERYL H. LIPMAN
CHIEF UNITED STATES DISTRICT JUDGE