RWJ Management Co., Inc. v. BP Products North America, Inc.

Federal 7th Circuit Court
Civil Court
Supplemental Jurisdiction
Citation
Case Number: 
No. 11-1268
Decision Date: 
February 16, 2012
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed
Dist. Ct. did not abuse its discretion in relinquishing supplemental jurisdiction and remanding two state-law claims alleging violation of Ill. Franchise Disclosure Act where plaintiff on eve of trial informed Dist. Ct. that it would be withdrawing its sole federal claim under Robinson-Patman Act and proceed only on its state-law claims. Once all federal claims drop out of case, general presumption arises in favor of remanding matter back to state court, and Dist. Ct. did not abuse its discretion in remanding case to state court where instant state-law claims were complex and raised unsettled legal issues. Fact that remand occurred just prior to start of trial did not require different result where pre-trial rulings focused mainly on discovery issues, as opposed to substantive issues of case.