Lawson v. West Contra Costa Unified School District

Background

Brandon William Lawson, a former substitute teacher in West Contra Costa Unified School District, sued the district and two individual district employees in Contra Costa County Superior Court after the district fired him on June 12, 2025. His original complaint asserted four California-law causes of action and one cause of action alleging that the defendants violated his First Amendment right to protected speech.

The defendants removed the case to federal court on August 21, 2025, relying on federal-question jurisdiction created by the First Amendment claim. Lawson then moved to remand the case to state court and submitted an amended complaint deleting that claim and references to it. The defendants initially stated that they would not oppose remand if Lawson properly filed and served the amended complaint. After Lawson filed it, however, the defendants continued to oppose remand, arguing that the amended complaint still articulated a federal question through its requests for relief.

Legal Standard

The court explained that the party seeking removal bears the burden of showing that federal jurisdiction exists. If the federal court lacks subject-matter jurisdiction before final judgment, the court must remand the action to state court.

The defendants relied on Alvarez v. Hill, which the court understood to say that a complaint filed in federal court may be read broadly to include federal legal theories even if it does not identify their precise statutory or constitutional source. The court found that principle inapplicable because this case involved an amended complaint that removed the federal cause of action that had supported removal.

Court’s Analysis

The court found the Supreme Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger directly applicable. Under that decision, deleting all federal claims from a complaint after removal eliminates federal-question jurisdiction, and the court’s related authority over state-law claims also ends. The court concluded that the amended complaint no longer contained the First Amendment cause of action and that the court therefore lacked jurisdiction.

The court also stated that the defendants’ earlier representation that they would not oppose remand if Lawson properly filed and served the amended complaint was a compelling reason to decline related jurisdiction, particularly because Lawson then did what the defendants had requested.

Disposition

The court GRANTED Lawson’s Motion to Remand. The action was REMANDED to Contra Costa County Superior Court.