Carlsbad Technology, Inc. v. HIF Bio, Inc.

556 U.S. 635 (2009)

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Carlsbad Technology, Inc. v. HIF Bio, Inc.

United States Supreme Court
556 U.S. 635 (2009)

  • Written by Haley Gintis, JD

Facts

HIF Bio, Inc. (plaintiff) filed a complaint in a state court against Carlsbad Technology, Inc. (defendant). The complaint alleged violations of state and federal patent law. Carlsbad removed the case to federal court under 28 U.S.C. § 1441(c), which allows a case in state court to be removed to federal court if the case includes at least one claim that invokes federal jurisdiction. After the case was removed, Carlsbad motioned to dismiss the only federal claim in the suit. Carlsbad argued that HIF Bio had failed to state a claim upon which relief could be granted in violation of Federal Rule of Civil Procedure 12(b)(6). The district court granted the motion and dismissed the claim. The district court then remanded the case to state court, citing 28 U.S.C. § 1367(c)(3), which gives a federal court the authority to decline supplemental jurisdiction over a claim if all claims that grant the court original jurisdiction have been dismissed. Carlsbad appealed the district court’s decision, arguing that the district court should have exercised supplemental jurisdiction to decide the case because the state patent-law claims implicate federal patent-law claims. The court of appeals denied reviewing the appeal on the ground that under 28 U.S.C. §§ 1447(c), (d), a federal appellate court may not review remands for lack of subject-matter jurisdiction. The decision was appealed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Concurrence (Breyer, J.)

Concurrence (Scalia, J.)

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