Bergman v. State of Nebraska, 4:20-cv-03001

Case originally filed in Douglas County, Nebraska; defendants removed to federal court on Jan. 2, 2020, asserting a § 1983 federal-question claim and invoking supplemental jurisdiction for related state-law claims.
Plaintiff Bergman asserted § 1983 claims (now dismissed as to other defendants) and state-law claims for negligence and medical malpractice against the State of Nebraska—the only remaining defendant.
Earlier stipulations dismissed Dawson County, Douglas County, and Correct Care Solutions; only State of Nebraska remains and only state-law claims persist.
The federal court had limited substantive involvement; parties proceeded with discovery and the court had not extensively expended resources on the case.
The State filed a motion for summary judgment on Dec. 27, 2021, which the federal court had not yet decided.
The court declined to exercise supplemental jurisdiction over the remaining state-law claims, remanded the case to Douglas County District Court, and denied the State's summary-judgment motion without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal court should continue to exercise supplemental jurisdiction over remaining state-law claims after federal claims are gone	Bergman sought remand of his state-law negligence and malpractice claims to state court	Defendants originally removed asserting federal-question jurisdiction and relied on supplemental jurisdiction to keep state claims in federal court; the State sought summary judgment in federal court	Court exercised discretion under 28 U.S.C. § 1367 and declined to retain supplemental jurisdiction; remanded the state-law claims to state court
Whether discretionary factors (judicial economy, convenience, fairness, comity) favor retention or remand	Bergman argued remand was appropriate because federal court had not substantially invested resources and state court is better suited to decide state-law issues	Defendants implicitly favored federal resolution (e.g., by filing summary-judgment motion) to resolve claims in federal forum	Court found factors (limited federal involvement, comity, fairness, and no obvious inconvenience) weighed in favor of remand
Disposition of State of Nebraska's summary-judgment motion filed in federal court	Bergman effectively argued the motion should be decided in state court after remand	State moved to resolve the case via summary judgment in federal court	Court denied the motion without prejudice to reassertion in state court following remand

Lindsey v. Dillard’s, Inc., 306 F.3d 596 (8th Cir. 2002) (district court retains discretion to remand state-law claims after dismissal of federal claims)
Carnegie–Mellon Univ. v. Cohill, 484 U.S. 343 (U.S. 1988) (courts should weigh judicial economy, convenience, fairness, and comity when deciding whether to remand)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (U.S. 1966) (courts should avoid needless decisions of state law to respect comity and promote justice)