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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Manal Farhan v. 2715 NMA LLC (2025)

Citation
Manal Farhan v. 2715 NMA LLC (2025)
Parent Document
Manal Farhan v. 2715 NMA LLC (2025)
Effective Date
2025-12-04

Other Sections in This Document (43)

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C. Interference Under § 3617
    Farhan’s § 3617 claim fails for similar reasons. Interference
under § 3617 requires a showing of “a pattern of harassment”
that is “motivated by an intent to discriminate.” Watters, 48
F.4th at 785, 787 (quoting Bloch, 587 F.3d at 783). Farhan has
alleged no “pattern” here—she brings her action on the basis
of one action enforcing defendants’ “neutrality” policy. Nor,
as discussed above, has she pled sufficient facts for us to infer
that this action was motivated by an intent to discriminate.
   D. State Law Claims
    Farhan makes one final argument—that the district court
erred when it dismissed without prejudice her state law
claims instead of remanding them to state court. A remand
may better “promote the values of economy, convenience,
fairness, and comity,” but it is ultimately in the district court’s
discretion whether to dismiss without prejudice or remand to
state court. See Robles v. City of Fort Wayne, 113 F.3d 732, 738
(7th Cir. 1997) (quoting Carnegie-Mellon Univ. v. Cohill, 484
U.S. 343, 352–53 (1988), superseded by statute as recognized by
Royal Canin U.S.A., Inc. v. Wullschleger, 604 U.S. 22, 39–41
(2025)). And “[t]he usual practice in this circuit is for district
courts to dismiss without prejudice state supplemental claims
whenever all federal claims have been dismissed prior to
trial.” Hagan v. Quinn, 867 F.3d 816, 830 (7th Cir. 2017) (inter-
nal quotation marks omitted). Farhan provides no argument
for why taking the usual course in this instance was an abuse
of discretion; accordingly, we find none.
                       III. Conclusion
   We close where we started: stressing that we decide this
case on narrow grounds, limited to the arguments Farhan
18                                                No. 24-1532