Facts
- Kentucky plaintiffs sued Thermtron Products, Inc. (an Indiana corporation) and its employee (an Indiana citizen) in Kentucky state court for damages from an automobile accident.
- Defendants removed the case to the U.S. District Court for the Eastern District of Kentucky under 28 U.S.C. §§ 1441(a) and 1446 based on diversity jurisdiction.
- The district judge acknowledged that removal was proper and that the federal court had jurisdiction.
- The district judge nonetheless remanded the case to state court solely because a congested federal docket would delay trial.
- Defendants sought mandamus or prohibition in the Sixth Circuit to vacate the remand order.
- The Sixth Circuit denied relief, concluding that 28 U.S.C. § 1447(d) barred review of the remand order “on appeal or otherwise.”
- The Supreme Court granted certiorari.
Issues
- Whether a federal district court may remand a properly removed case within its jurisdiction solely due to docket congestion and anticipated trial delay.
- Whether 28 U.S.C. § 1447(d) bars appellate review, including by mandamus, of a remand order entered on grounds not authorized by § 1447(c).
Decision
- The Supreme Court reversed.
- A district court exceeds its statutory authority by remanding a properly removed case for reasons not authorized by § 1447(c), such as docket congestion.
- Section 1447(d), read in conjunction with § 1447(c), does not bar review by mandamus of a remand order based on non-§ 1447(c) grounds.
- Mandamus is an appropriate remedy to require the district court to exercise the jurisdiction conferred by the removal statutes.
Legal Principles
- A district court may remand a removed case only on the grounds specified in § 1447(c) (at the time: removal “improvidently and without jurisdiction”), not on case-management considerations.
- The review bar in § 1447(d) applies to remand orders issued pursuant to § 1447(c); it does not insulate remands resting on unauthorized, extra-statutory grounds.
- When a district court refuses to exercise properly invoked removal jurisdiction by issuing an unauthorized remand, an appellate court may use mandamus to compel the court to adjudicate the case.
Conclusion
The Court held that federal courts cannot remand properly removed cases due to docket congestion and that § 1447(d) does not preclude mandamus review of remand orders that exceed the authority granted by § 1447(c).