## Facts

- Chicago’s Landmarks Ordinance is administered by the Commission on Chicago Historical and Architectural Landmarks.
- The Commission preliminarily determined that seven buildings, including two mansions owned by the International College of Surgeons (ICS), qualified for designation as a landmark district.
- The City Council later enacted an ordinance formally designating the landmark district, including ICS’s properties.
- After the preliminary determination but before final designation, ICS contracted to redevelop the properties, including substantial demolition and construction of a high-rise condominium tower.
- ICS applied to the Commission for demolition permits; the Commission denied the applications, finding the proposed demolition would harm significant historic and architectural features.
- ICS sought judicial review in Illinois state court under the Illinois Administrative Review Law, requesting on-the-record review of the Commission’s decisions and asserting federal and state constitutional challenges (including due process, equal protection, and takings).

## Issues

1. Whether a state-court action seeking on-the-record judicial review of local administrative decisions is removable to federal court when the complaint also pleads federal constitutional claims.
2. Whether a federal district court may exercise supplemental jurisdiction over the state-law administrative review claims that arise from the same administrative action as the federal claims.

## Decision

- The Supreme Court reversed the Seventh Circuit and remanded.
- Because ICS’s well-pleaded complaints raised federal constitutional claims, the case fell within federal-question jurisdiction and was removable under 28 U.S.C. §§ 1331 and 1441(a).
- The district court could exercise supplemental jurisdiction under 28 U.S.C. § 1367(a) over the related state-law administrative review claims, which formed part of the same case or controversy.
- The Court rejected a categorical rule barring federal jurisdiction merely because some claims sought on-the-record review under state administrative review procedures.
- The Court noted that district courts retain discretion under § 1367(c) to decline supplemental jurisdiction over state-law claims in appropriate circumstances.

## Legal Principles

- A civil action filed in state court is removable under 28 U.S.C. § 1441(a) if the federal district court would have original jurisdiction under 28 U.S.C. § 1331 based on federal issues appearing on the face of the plaintiff’s well-pleaded complaint.
- Under 28 U.S.C. § 1367(a), once original jurisdiction exists over federal claims, the federal court may hear related state-law claims forming part of the same case or controversy, including state-law claims seeking on-the-record review of local administrative findings.
- Neither § 1441(a) nor § 1367 contains an implied exclusion for state administrative review claims; the presence of such claims does not negate federal jurisdiction when federal claims are properly pleaded.
- Even when supplemental jurisdiction is authorized, a district court may decline to exercise it under § 1367(c) based on statutory factors such as predominance of state issues or novel state-law questions.

## Conclusion

When a plaintiff combines federal constitutional challenges with state-law administrative-record review claims arising from the same local administrative action, the case may be removed to federal court on the federal claims, and the district court may hear the related state-law review claims under supplemental jurisdiction, subject to discretionary remand.


City of Chicago v. International Coll. of Surgeons, 522 U.S. 156 (1997)