Dennis Packard v. Farmers Insurance Co. of Columbus, 423 F. App'x 580

Plaintiffs' home was destroyed in 2006 with about $138,000 in losses; Farmers denied the SFIP coverage on the basis that a landslide caused the damage.
Plaintiffs sued in Ohio state court for breach of the SFIP and fraudulent misrepresentation; Farmers removed to federal court under multiple theories including NFIA fiduciary duties and WYO program.
District court initially found federal jurisdiction proper due to SFIP administration; Plaintiffs amended the complaint in 2007 abandoning federal SFIP claims and asserting only state-law claims.
Discovery proceeded in federal court; Farmers moved for summary judgment on preemption grounds; the district court later remanded to state court, stating no federal claims remained and emphasizing comity and economy.
On appeal, Farmers challenges the remand decision; the Sixth Circuit affirms, holding jurisdiction to review under 28 U.S.C. § 1447(d) and upholding the district court’s discretion to remand state-law claims.
The panel concludes that comity and judicial economy favored remand after all federal claims were dismissed, with no substantial savings to outweigh considerations against deciding state-law issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the remand decision is reviewable on appeal	Farmers; seeks review under §1447(d) (remand review permitted).	Plaintiffs contend the remand decree is unreviewable because no federal claims remain.	Remand review is permissible under §1447(d); appellate review conducted.
Whether the district court properly declined supplemental jurisdiction over state-law claims	Remand was improper; federal jurisdiction should persist due to the prior removal and potential efficiency.	Remand was proper; comity and economy favored state-court adjudication once federal claims were dismissed.	District court did not abuse discretion; comity and economy justified remand.
Whether the district court had subject-matter jurisdiction over the amended complaint	Amended complaint eliminated federal claims, undermining jurisdiction.	Removal preserved jurisdiction under supplemental authority; dismissal of federal claims does not defeat jurisdiction.	Subject-matter jurisdiction remained via supplemental jurisdiction; amendment did not defeat jurisdiction.

Harper v. AutoAlliance Int'l, Inc., 392 F.3d 195 (6th Cir. 2004) (claims form part of same case or controversy; supplemental jurisdiction proper)
Cohill v. Green, 484 U.S. 343 (U.S. 1988) (federalism and jurisdictional balancing in supplemental jurisdiction)
Moon v. Harrison Piping Supply, 465 F.3d 719 (6th Cir. 2006) (strong presumption against exercising supplemental jurisdiction after federal claims dismissal)
Experimental Holdings, Inc. v. Farris, 503 F.3d 514 (6th Cir. 2007) (post-dismissal jurisdiction considerations in supplemental jurisdiction decisions)
Musson Theatrical v. Fed. Express Corp., 89 F.3d 1244 (6th Cir. 1996) (when federal claims are dismissed, consider remand to state court for efficiency)
Gibbs, United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (U.S. 1966) (federal-question claims and state-law claims interplay in jurisdiction)
DePiero v. City of Macedonia, 180 F.3d 770 (6th Cir. 1999) (factors for remand and judicial economy in locational remand analysis)
Carlsbad Tech., Inc. v. HIF Bio, Inc., 556 U.S. 635 (U.S. 2009) (subject-matter jurisdiction and the significance of amendment after removal)