Clarence Enochs v. Lampasas County, 641 F.3d 155

Enochs filed a Texas state-court petition on Dec 29, 2008 alleging federal §1983/§1985 and state claims under Texas Gov't Code §614 and common-law defamation.
Lampasas County removed the case to federal court on Jan 26, 2009 under 28 U.S.C. §1441.
County moved to dismiss the federal §1985 and state whistleblower claims; Enochs amended to delete all federal claims on Mar 11, 2009.
District court denied remand on Apr 20, 2009, finding removal proper and allowing the amended complaint; it dismissed the §1985 claim and did not resolve the whistleblower claim.
After amendment, only Texas state-law claims remained; discovery proceeded and County moved for summary judgment on these claims.
The district court granted summary judgment on all Texas state-law claims on Dec 2, 2009, prompting Enochs’s appeal seeking remand and reversal of the summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by not remanding pendent state claims.	Enochs	Lampasas County	Yes, remand required
Whether, after federal claims were dismissed, the court should apply §1367(c) factors and Carnegie-Mellon factors.	Enochs	Lampasas County	Remand appropriate; factors favor remand
Whether forum manipulation was a controlling factor to retain jurisdiction.	Enochs engaged in minimal manipulation	Remand remains proper despite manipulation concerns	Forum manipulation not controlling; factors still favor remand
Whether Parker & Parsley controls the outcome given the case posture.	Enochs	Lampasas County	Parker & Parsley not controlling; overall factors favor remand here
Whether the district court should have reconsidered jurisdiction when federal claims were deleted.	Enochs	Lampasas County	Yes, reconsideration required and remand favored

Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (set forth the balance of common-law factors and forum considerations for pendent jurisdiction)
Gibbs v. United Mine Workers, 383 U.S. 715 (1966) (discretion guided by economy, convenience, fairness, comity)
McClelland v. Gronwaldt, 155 F.3d 507 (5th Cir. 1998) (treats 1367(c) factors as balancing principles (overruled on other grounds))
Brookshire Bros. Holding, Inc. v. Dayco Prods., Inc., 554 F.3d 595 (5th Cir. 2009) (judicial economy and convenience weigh on remand decisions)
Mendoza v. Murphy, 532 F.3d 342 (5th Cir. 2008) (balance statutory factors in 1367(c) with common-law factors)
Parker & Parsley Petroleum Co. v. Dresser Industries, 972 F.2d 580 (5th Cir. 1992) (factors weighing in remand vs. retention; Parker & Parsley cautions against forum manipulation)
Beiser v. Weyler, 284 F.3d 665 (5th Cir. 2002) (removal/remand context and balance of factors in pendent jurisdiction)
Guzzino v. Felterman, 191 F.3d 588 (5th Cir. 1999) (recognizes wide discretion in retaining/remanding pendent state-law claims)
Boelens v. Redman Homes, Inc., 759 F.2d 504 (5th Cir. 1985) (forum manipulation concerns in pendent jurisdiction)
Wong v. Stripling, 881 F.2d 200 (5th Cir. 1989) (early-stage federal claim dismissal affecting remand rule)