Bozeman Multi-Level Shopping Complex a/k/a Bozeman Hotel Owners’ Association, on its behalf and on the behalf of individual owners v. City of Bozeman, a municipal corporation

Summary

The United States District Court for the District of Montana granted the parties’ joint motion to remand after the plaintiff’s amended complaint removed all federal-law claims. Relying on Royal Canin U.S.A., Inc. v. Wullschleger, the court held that federal-question and supplemental jurisdiction no longer supported the case and directed the Clerk to remand it to Montana’s Eighteenth Judicial District Court in Gallatin County.

Holdings

1. When a plaintiff amends the operative complaint after removal to eliminate all federal-law claims, federal-question jurisdiction dissolves and supplemental jurisdiction over the remaining state-law claims disappears; the federal court must remand the case to state court.

Questions Presented

1. Whether a federal court must remand a removed action when the plaintiff’s post-removal amended complaint eliminates all federal-law claims and leaves only state-law claims.

Disposition

remanded