When a federal claim for battery against Watson has been dismissed, can the remaining state law claims be dismissed without prejudice?

The district court expressly found that the officers had not committed a battery against Watson. Because the uncontroverted facts established that the officers acted from objectively reasonable fears for their safety, their actions were privileged as a matter of California law. See Gilmore v. Superior Court, 230 Cal.App.3d 416, 281 Cal.Rptr. 343 (1991). The district court accordingly did not err in dismissing the battery claim.

It is not clear from the record on what ground the district court dismissed the remaining state law claims. We assume, therefore, that the claims were dismissed without prejudice because no federal claims remained before the court. Dismissal on that ground was proper. See United Mine Workers v. Gibbs, 383 U.S. 715, 726 (1966) (stating that when federal claims are dismissed before trial, then state claims should be dismissed as well).