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Borough of West Mifflin v. Lancaster

United States Court of Appeals for the Third Circuit
45 F.3d 780 (3d Cir. 1995)


Facts

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.

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Holding and Reasoning (Pratt, J.)

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