Hodroff v. JPMorgan Chase & Co.
- Proceeding
- district
- Area
- civil
- Panel
- Andrew G. Schopler (author)
Analysis
The court considered whether to exercise supplemental jurisdiction over the plaintiff's remaining state-law claims after the sole federal claim was dismissed and the plaintiff failed to file an amended complaint. The court declined to exercise supplemental jurisdiction and remanded the case to the San Diego County Superior Court.
| What the court decided | The model |
|---|---|
Decline to exercise supplemental jurisdiction over state claims and remand case to state court“Hodroff has not filed amended complaint, and the Court declines to exercise supplemental jurisdiction over his state claims. ... This case is thus REMANDED to Superior Court of California, County of San Diego Central Division, Case No. 24CL025842C.” | agree with court The decision follows from 28 U.S.C. § 1367(c), which allows a district court to decline supplemental jurisdiction when it has dismissed all claims over which it has original jurisdiction. The court correctly applied the Ninth Circuit's guidance from Sanford v. MemberWorks, Inc., which states that in the usual case where all federal claims are eliminated before trial, the factors of judicial economy, convenience, fairness, and comity point toward declining jurisdiction. The record indicates the sole federal claim was dismissed and no amended complaint was filed, triggering the standard presumption against retaining state claims. |
The order itself: sound — The order is procedurally correct and relies on the appropriate statutory provision (28 U.S.C. § 1367(c)) and binding Ninth Circuit precedent (Sanford v. MemberWorks, Inc.) to support the decision to remand. The reasoning is concise but sufficient for a standard remand order where the federal claim has been dismissed and no amendment was filed.
Opinion
1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 || Matthew HODROFF, Case No.: 25-cv-0041-AGS-JLB Plant | ORDER REMANDING CASE TO 5 || V- STATE COURT 6 || JEPMORGAN CHASE BANK, et al., 7 Defendants. 8 9 This Court previously dismissed plaintiff Matthew Hodroff’s sole federal claim and 10 || gave him until June 9, 2025, to amend his complaint. (See ECF 11.) Hodroff has not filed 11 amended complaint, and the Court declines to exercise supplemental jurisdiction over 12 ||his state claims. See 28 U.S.C. § 1367(c). “In the usual case in which all federal-law claims 13 eliminated before trial, the balance of factors to be considered under the pendent 14 jurisdiction doctrine—judicial economy, convenience, fairness, and comity—will point 15 || toward declining to exercise jurisdiction over the remaining state-law claims.” Sanford v. 16 || MemberWorks, Inc., 625 F.3d 550, 561 (9th Cir. 2010). This case is thus REMANDED to 17 Superior Court of California, County of San Diego Central Division, Case 18 || No. 24CL025842C. (See ECF 1, at 14); 28 U.S.C. § 1447(c). 19 || Dated: June 10, 2025 21 Hon. Andrew G. Schopler United States District Judge 23 24 25 26 27 28
Cites, in this corpus
- Sanford v. MemberWorks, Inc. 18-15662 · 2010-10-25