Borough of West Mifflin v. Lancaster
United States Court of Appeals for the Third Circuit
45 F.3d 780 (3d Cir. 1995)
Allan Lindsey and Randall Coughanour were harassed and eventually banned from returning to a mall for seemingly no reason. When they subsequently returned to the mall, Lindsey and Coughanour were arrested. They filed a malicious prosecution suit in state court against the Borough of West Mifflin (West Mifflin) (plaintiff), the arresting officer, and the mall owners. The suit contained both state and federal claims. West Mifflin removed the case to the United States District Court for the Western District of Pennsylvania. Lindsey and Coughanour filed a motion to remand the case to state court. District Judge Lancaster (defendant), agreeing that state law issues predominated the case, remanded the entire case to state court, including the federal claims, under 28 U.S.C. § 1441(c). Section 1441(c) provided that when a separate and independent federal claim is joined with a state claim, the entire case may be removed to federal court and the federal district court may then either hear all of the claims or remand the entire case if the state law issues predominate. West Mifflin petitioned for a writ of mandamus, alleging that Lancaster had erred when he remanded the entire case to state court.
Rule of Law
Holding and Reasoning (Pratt, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 153,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,500 briefs, keyed to 184 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.