Roberts v. Eclipz.io, Inc.

Background

Defendant James Rautner removed the action from the Santa Clara County Superior Court to the U.S. District Court for the Northern District of California. He asserted federal-question jurisdiction under 28 U.S.C. § 1331 because Paul Roberts had brought a claim under the Racketeer Influenced and Corrupt Organizations Act, commonly called RICO.

Roberts and Rautner stipulated to the filing of an amended complaint. The opinion says the amended complaint would, among other things, dispose of Roberts’s RICO claim and eliminate the basis for federal subject-matter jurisdiction. The parties also stipulated that the action should be returned to the Santa Clara County Superior Court.

Rulings

The court granted the parties’ stipulation regarding the proposed amended complaint. It directed Roberts to file the proposed amended complaint as a separate electronic court filing by March 19, 2025.

The court did not enter the proposed remand order itself. It explained that the proposed order concerned a dispositive matter and that, without the consent of all parties, the magistrate judge lacked authority to enter it. The court therefore recommended that, after Roberts files the amended complaint, the newly assigned district judge approve the parties’ stipulated request to remand the case to the Santa Clara County Superior Court. Any party may file objections to that recommendation within 14 days under Federal Rule of Civil Procedure 72(b) and the court’s local rules.

Effect

The amended-complaint stipulation was granted. The recommendation to return the case to state court remained for review by the newly assigned district judge; the opinion did not state that the final remand order had been entered.