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McConnell v. ABC-Amega, Inc.

Citation: 338 F. App'x 24Docket: No. 08-2563-cv

Court: Court of Appeals for the Second Circuit; July 2, 2009; Federal Appellate Court

Narrative Opinion Summary

In this case, Gregory McConnell filed employment discrimination claims against ABC-Amega, Inc. and its agents, asserting state law causes of action and alleged constitutional violations under the Fifth and Fourteenth Amendments. This led to the removal of the case to federal court pursuant to 28 U.S.C. 1441. After McConnell clarified he did not intend to pursue federal claims, he sought to remand the case to state court. The District Court granted the remand, finding no remaining federal claims, and denied McConnell's request for attorneys' fees, reasoning that the removal had a reasonable basis. McConnell did not appeal the remand order but argued the removal was improper and contested the denial of attorneys' fees. However, the court held that his failure to timely object under Rule 72 of the Federal Rules of Civil Procedure constituted a waiver of his objection to the removal's basis. The court also upheld that it retained jurisdiction to rule on attorneys' fees post-remand. Ultimately, the court affirmed the District Court's judgment, denying McConnell's claims regarding improper removal and attorneys' fees.

Legal Issues Addressed

Attorneys' Fees in Remand Cases

Application: The court ruled that attorneys' fees were not warranted as the removal had a reasonable basis, despite the remand.

Reasoning: The District Court remanded the case, concluding that no federal claims remained and that ABC had a reasonable basis for removal, thus denying McConnell's request for attorneys' fees.

Objections to Magistrate Judge's Orders under Rule 72

Application: The court found that McConnell waived his objections by not filing them within the ten-day period specified for such objections under the rule.

Reasoning: McConnell waived his objection regarding the reasonable basis for removal since he failed to file written objections within the ten-day period required under Rule 72 of the Federal Rules of Civil Procedure.

Remand of Cases to State Court

Application: The District Court remanded the case to state court upon clarification that no federal claims were intended to be pursued.

Reasoning: McConnell sought to remand the case back to state court, clarifying that he did not intend to pursue constitutional claims.

Removal Jurisdiction under 28 U.S.C. 1441

Application: The court determined that the removal of the case to federal court was appropriate due to initially alleged federal claims, even though those claims were later withdrawn.

Reasoning: ABC to remove the case to federal court under 28 U.S.C. 1441.

Retention of Jurisdiction over Attorneys' Fees

Application: The court confirmed that it retained jurisdiction to decide on attorneys' fees even after the case was remanded to state court.

Reasoning: Ultimately, the court affirmed the District Court's judgment, confirming that it retained jurisdiction to decide on attorneys' fees even after the remand.