Williams v. Sierra Donor Services: ADA and USERRA Claims Defeat Remand

Bryan Williams worked for Sierra Donor Services, later identified as DCI Donor Services, Inc., for approximately seventeen years. Williams was a Black United States Army veteran over the age of forty and had been diagnosed with service-connected post-traumatic stress disorder. During his employment, Williams consistently received positive performance evaluations.

In April 2024, Williams applied for a Quality Administrative position. He alleged that he met the qualifications for the role but was not granted an interview. The position was awarded to a younger employee with less experience. In May 2024, Williams filed a charge with the Equal Employment Opportunity Commission and later received a right-to-sue notice.

After filing the administrative complaint, Williams received his first disciplinary write-up in October 2024. In November 2024, he received a negative performance evaluation related to documentation errors and absences. In February 2025, Sierra Donor Services placed Williams on a performance improvement plan.

Claims Asserted in State Court

Williams filed a civil action in the Sacramento County Superior Court on June 23, 2025. His complaint asserted multiple causes of action under California law, including race and age discrimination, retaliation, failure to accommodate a disability, hostile work environment, whistleblower retaliation, interference with rights under the California Family Rights Act, and discrimination based on military and veteran status.

The complaint also asserted claims arising under federal law. Williams alleged disability discrimination in violation of the Americans with Disabilities Act and discrimination based on military service in violation of the Uniformed Services Employment and Reemployment Rights Act.

Removal to Federal Court

Sierra Donor Services removed the action to the United States District Court for the Eastern District of California on July 16, 2025. The notice of removal asserted that the court had federal question jurisdiction because the complaint included claims created by federal law. The notice also asserted supplemental jurisdiction over the remaining state-law claims because they arose from the same employment relationship.

Williams moved to remand the case to state court. He asserted that the references to federal statutes in his complaint were contextual and that his claims did not arise under federal law. He also requested an award of attorney’s fees associated with the removal.

Federal Question Jurisdiction Analysis

The court examined the complaint under the well-pleaded complaint rule. It reviewed whether federal law created any of the causes of action asserted. The court identified two claims that expressly relied on federal statutes: the disability discrimination claim under the Americans with Disabilities Act and the military-status discrimination claim under USERRA.

The court determined that these claims were not mere references to federal law but independent causes of action created by federal statutes. Because the complaint asserted claims arising under federal law on its face, the court concluded that it had original jurisdiction under 28 U.S.C. § 1331.

The court rejected Williams’s argument that USERRA did not support federal jurisdiction. The statute expressly grants federal district courts jurisdiction over USERRA claims brought by individuals against private employers.

Supplemental Jurisdiction Over State-Law Claims

The court next addressed whether it could exercise jurisdiction over the remaining state-law claims. It found that those claims arose from the same set of facts as the federal claims, including Williams’s employment history, disciplinary actions, and alleged retaliation.

Because the claims derived from a common nucleus of operative fact, the court concluded that supplemental jurisdiction was proper under 28 U.S.C. § 1367. Based on that conclusion, the court did not reach the parties’ arguments concerning diversity jurisdiction or the forum-defendant rule.

Attorney’s Fees Request

Williams requested attorney’s fees under 28 U.S.C. § 1447(c), asserting that the removal was improper. The court denied that request. It determined that Sierra Donor Services had an objectively reasonable basis for removal because the complaint asserted claims created by federal law.

The Court’s Decision

The court denied Williams’s motion to remand. It held that federal question jurisdiction existed based on the ADA and USERRA claims and that supplemental jurisdiction extended to the remaining state-law claims. The request for attorney’s fees was denied, and the case proceeded in federal court.

Assistance With USERRA Matters

If you’ve experienced issues involving military service and employment rights, Whitcomb Selinsky PC handles USERRA matters. Reach out to our team through our contact page to learn how our team can assist with your claim.