District Court Declines to Exercise Supplemental Jurisdiction and Dismisses State Law Claims


On November 7, 2016, a Southern District of Florida court sua sponte declined to exercise its supplemental authority and dismissed a plaintiff’s state law claims in a TCPA action. In Travis v. Residential Credit Solutions, Inc., the plaintiff alleges that defendant placed hundreds of calls to his cellular phone using an ATDS in an effort to collect a debt. From these allegations, the plaintiff filed an individual complaint consisting of three claims: two claims asserting violations of the Florida Consumer Collection Practices Act (“FCCPA”) and one claim asserting a violation of the TCPA.