Carnegie-Mellon Univ. v. Cohill

Supreme Court of United States
484 U.S. 343 (1988)

ELI5:

Rule of Law:

Under the doctrine of pendent jurisdiction, a federal district court has the discretion to remand a properly removed case to state court when all federal-law claims have been eliminated and only pendent state-law claims remain.

Facts:

William Boyle worked for Carnegie-Mellon University (CMU) under the supervision of John Kordesich.
CMU discharged William Boyle from his employment.
William Boyle alleged that his discharge was based on age discrimination and also constituted wrongful discharge, breach of contract, and other torts under state law.
Carrie Boyle, William Boyle's wife, alleged that her husband's discharge caused her to suffer a loss of consortium and companionship.

Procedural Posture:

William and Carrie Boyle (respondents) filed suit against Carnegie-Mellon University and John Kordesich (petitioners) in a Pennsylvania state trial court.
Petitioners removed the action to the U.S. District Court for the Western District of Pennsylvania based on the federal age-discrimination claim.
Respondents subsequently moved to amend their complaint to delete the federal claim and filed a conditional motion to remand the remaining state-law claims to state court.
The District Court granted the motion to amend and remanded the case to the state trial court.
Petitioners sought a writ of mandamus from the U.S. Court of Appeals for the Third Circuit to compel the District Court to vacate its remand order.
A three-judge panel of the Third Circuit initially granted the writ.
The Third Circuit granted a rehearing en banc, which vacated the panel's decision.
The en banc court divided evenly, resulting in a denial of the petition for mandamus, which left the District Court's remand order in effect.
The U.S. Supreme Court granted certiorari.

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Issue:

Does a federal district court have discretion under the doctrine of pendent jurisdiction to remand a properly removed case to state court after all federal-law claims that formed the basis for removal have been dismissed from the action?

Opinions:

Majority - Justice Marshall

Yes. A district court has the discretion to remand a removed case involving pendent state-law claims when retaining jurisdiction would be inappropriate. The doctrine of pendent jurisdiction, as established in Mine Workers v. Gibbs, is one of discretion, flexibility, and is guided by considerations of judicial economy, convenience, fairness, and comity. While Gibbs spoke of dismissal, remand is a preferable alternative in many circumstances, particularly when the statute of limitations on a state-law claim has expired, as dismissal would unfairly bar the plaintiff's claim. The federal removal statute's silence on this issue does not preclude the power to remand, especially since the statute is also silent on the conceded power to dismiss. The Court's prior decision in Thermtron Products, Inc. v. Hermansdorfer is distinguishable because it involved a non-discretionary basis for jurisdiction (diversity), whereas pendent jurisdiction is inherently discretionary.

Dissenting - Justice White

No. A federal district court lacks the authority to remand a properly removed case for reasons not explicitly authorized by statute. Congress has enacted specific provisions governing remand, and this situation is not among them; the Court's creation of an inherent remand power renders these statutes superfluous. This holding is inconsistent with Thermtron, which held that cases may only be remanded for reasons authorized by statute. Furthermore, this decision allows for plaintiff-driven forum manipulation, enabling a plaintiff to defeat a defendant's statutory right of removal by simply deleting their federal claim after removal. The majority's concern over statutes of limitation is overstated, as many states have 'saving clauses' that protect plaintiffs in such situations.

Analysis:

This decision resolves a circuit split and clarifies the scope of a federal court's authority over removed cases involving pendent claims. It establishes that the discretionary principles of pendent jurisdiction from Gibbs apply equally to the choice between dismissal and remand after federal claims are dropped. By prioritizing judicial economy, fairness, and comity over a rigid statutory interpretation of remand authority, the Court empowers district judges with greater flexibility to manage their dockets and respect the role of state courts. This ruling may encourage plaintiffs to include federal claims in state court filings, knowing they can potentially return to a state forum if the federal claims are later dismissed.

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