Borough of West Mifflin v. Lancaster

Allan Lindsey and Randall Coughanour were banned from a mall and later arrested when they returned. They sued the Borough of West Mifflin (West Mifflin) (plaintiff), the arresting officer, and the mall owners in state court, raising both state and federal claims arising from the same harassment incident. West Mifflin removed the case to federal district court. District Judge Lancaster (defendant) found that state issues predominated and remanded the entire case, including the federal claims, under 28 U.S.C. § 1441(c). West Mifflin petitioned for a writ of mandamus, arguing that Lancaster had no authority to remand the federal claims this way.

Whether Section 1441(c) permits an entire removed case to be remanded to state court when the federal claim is joined with state-law claims arising from the same events, rather than being separate and independent from them.