Synchrony Bank v. Szanto

Summary

The court grants Plaintiff Synchrony Bank’s motion to remand a state-law breach-of-contract action to the Superior Court of California, County of San Diego. It holds that the complaint presents no federal question and that Defendant’s anticipated federal counterclaims cannot support removal jurisdiction.

Holdings

1. The complaint did not present a federal question because it asserted only a state-law breach-of-contract claim.
2. Anticipated or unfiled federal counterclaims cannot serve as the basis for removal or federal-question jurisdiction.

Questions Presented

1. Whether the district court had federal-question jurisdiction over a removed state-law breach-of-contract complaint.
2. Whether anticipated federal counterclaims could provide a basis for removal and federal-question jurisdiction.

Disposition

remanded