Civil Procedure – Removal – remand

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United States Court of Appeals For the Seventh Circuit

Civil

Civil Procedure – Removal – remand

When all federal claims have been dropped from a lawsuit removed to federal court, it was not an abuse of discretion to remand the case to state court, even if trial was only a few days away.

“When federal claims drop out of the case, leaving only state-law claims, the district court has broad discretion to decide whether to keep the case or relinquish supplemental jurisdiction over the state-law claims. A general presumption in favor of relinquishment applies and is particularly strong where, as here, the state-law claims are complex and raise unsettled legal issues. In certain limited circumstances, a substantial investment of the federal court’s time may overcome the presumption, although we defer to the district court’s judgment about when that threshold has been crossed. Here, the judge weighed the relevant factors and decided that the time she had spent on the case, though substantial, was not sufficiently related to the substance of the state-law claims to justify keeping the case in federal court. This was not an abuse of discretion.”

Affirmed.

11-1268 RWJ Management co. v. BP Products North America Inc.

Appeal from the United States District Court for the Northern District of Illinois, Pallmeyer, J., Sykes, J.