Gardea v. State of California

Summary

The United States District Court for the Eastern District of California adopted findings and recommendations granting the plaintiff's unopposed motion to remand. The court remanded the action to the Sacramento County Superior Court after the amended complaint eliminated the federal claim that supported removal, relying on the Supreme Court's decision in Royal Canin U.S.A., Inc. v. Wullschleger.

Holdings

1. When an amendment excises the federal-law claims that enabled removal, the federal court loses supplemental jurisdiction over the related state-law claims, and the case must be remanded to state court.
2. Plaintiff's motion to remand must be granted, and the action must be remanded to the Sacramento County Superior Court.

Questions Presented

1. Whether deletion of the federal claims that enabled removal eliminates the federal court's supplemental jurisdiction over related state-law claims.
2. Whether the action should be remanded to the Sacramento County Superior Court after the federal claims were excised from the amended complaint.

Disposition

remanded