Skinner v. Patel, 4:16-cv-01700

Plaintiffs (Kimberly Skinner et al.) sued several defendants in Florence County Court of Common Pleas and filed an amended complaint.
Three defendants removed the action to federal court asserting federal-question jurisdiction under 28 U.S.C. § 1331, with the other defendants' consent.
Plaintiffs moved to remand the case back to state court.
The Magistrate Judge issued a Report & Recommendation (R&R) recommending that the motion to remand be granted.
No party filed objections to the R&R. The District Court reviewed the record for clear error, adopted the R&R, granted remand, and directed the clerk to send a certified copy to the state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal-question jurisdiction exists such that removal was proper	Plaintiffs argued removal was improper and case should be remanded to state court	Removing defendants argued jurisdiction under 28 U.S.C. § 1331 supported federal removal	Court found no basis to retain the case, granted remand (adopting R&R)
Standard of review for R&R when no objections are filed	Plaintiffs relied on Magistrate's recommendation and no objection was needed	Defendants offered no objections to the R&R	Court applied clear-error review, found none, and adopted the R&R

Mathews v. Weber, 423 U.S. 261 (1976) (district court makes final determination on magistrate judge recommendations)
Camby v. Davis, 718 F.2d 198 (4th Cir. 1983) (no explanation required to adopt R&R absent objections)
Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005) (district court need only review for clear error when no timely objections are filed)