Roxana Dominguez v. Brenntag North America Inc., 2:19-cv-03419

Plaintiff Roxana Dominguez sued in Los Angeles County Superior Court on state-law wrongful-death claims arising from alleged talcum-powder exposure that caused her father’s death.
Defendant Johnson & Johnson removed the case to federal court under 28 U.S.C. § 1452, asserting the claims are "related to" a pending bankruptcy filed by talc supplier Imerys Talc America, Inc.
Defendant stated its intent to move to transfer venue to the District of Delaware, where Imerys’s bankruptcy is pending, to centralize thousands of related claims.
Plaintiff moved to remand to state court; the motion was fully briefed and submitted to the Central District of California.
The district court considered the equitable-remand factors under 28 U.S.C. § 1452(b), including judicial economy, comity, uniformity, prejudice to nondebtor parties, and the risk of inconsistent rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this court properly exercises jurisdiction under 28 U.S.C. § 1452	Remand is required because plaintiff filed in state court and her claims are purely state-law; federal removal is improper or should be remanded on equitable grounds	Removal was permissible because the claims are related to Imerys’s bankruptcy, invoking § 1452 removal and possible centralization in Delaware	Court assumed § 1452 removal but found equitable grounds to remand; denied federal retention
Whether equitable grounds favor remand (considering judicial economy, comity, uniformity, prejudice)	Remand is equitable: plaintiff is a California resident, litigation has been pending in state court, state coordination avoids inconsistent rulings, and plaintiff would be prejudiced by inconvenient transfer	Defendant urged waiting for District of Delaware to rule on venue and centralization; argued Delaware has authority to fix venue for bankruptcy-related claims	Court found factors (judicial economy, comity, statewide coordination, prejudice to plaintiff) favored remand and ordered remand to Los Angeles County Superior Court

In re TIG Ins. Co., 264 B.R. 661 (Bankr. S.D. Cal. 2001) (lists equitable factors for remand under § 1452)
Stichting Pensioenfonds ABP v. Countrywide Fin. Corp., 447 B.R. 302 (C.D. Cal. 2010) ("on any equitable ground" standard permits remand when relevant factors warrant it)
In re Roman Catholic Bishop of San Diego, 374 B.R. 756 (S.D. Cal. 2007) (discusses breadth of equitable-remand authority under § 1452)
W. Helicopters, Inc. v. Hiller Aviation, 97 B.R. 1 (E.D. Cal. 1988) (early articulation of equitable factors for remand)
McCarthy, 230 B.R. 1 (Bankr. D. Mass.) (state courts competent to resolve predominately state-law matters; comity supports remand)