Terrell Lott v. Comprehensive Behavioral Health Center of St. Clair County, Inc.

Summary

The court granted Plaintiff Terrell Lott’s motion to remand an employment-related action to Illinois state court. After Plaintiff amended her complaint to remove references to the Fair Labor Standards Act, the court concluded that the amended complaint raised no federal question and that subject matter jurisdiction was lacking.

Holdings

1. The First Amended Complaint did not raise a question of federal law because it omitted references to the FLSA and did not request liquidated damages.
2. Because the First Amended Complaint did not raise a federal question, the district court lacked subject matter jurisdiction and was required to remand the case to state court.

Questions Presented

1. Whether the complaint, as amended to remove references to the FLSA and liquidated damages, presented a federal question supporting removal jurisdiction.
2. Whether the federal district court had subject matter jurisdiction over the action after Plaintiff filed the First Amended Complaint.

Disposition

remanded