Harris v. Carwithen
- Edward Chen
- 3:22-cv-01505
- U.S. District Court · Northern District of California
- 2
In Harris v. Carwithen, Judge Chen granted Harris’s amendment request, remanded the case to state court, and denied screening as moot.
Michael Jay Harris and A Carwithen; the case was returned to Monterey County Superior Court, and the defendants’ screening request was denied as moot.
What happened
In Harris v. Carwithen, Michael Jay Harris asked the federal court to let him withdraw his complaint and return the case to Monterey County Superior Court. He provided an amended complaint filed there and said his claim was based on negligence and mental injuries.
The defendants argued that the amended complaint still included federal claims. Harris responded that the case was more appropriately handled in state court.
Judge Edward M. Chen treated Harris’s request as a motion to amend, granted it, and remanded the case because the amended complaint no longer contained federal claims. Judge Chen denied the defendants’ request to screen the complaint as moot.
The detailed version
- Harris v. Carwithen · No. 3:22-cv-01505
- Edward Chen
- Oct. 28, 2022
Background
Michael Jay Harris filed the action in Monterey County Superior Court. The complaint included several federal claims, and the defendants removed the action to the U.S. District Court for the Northern District of California.
Harris asked to “withdraw the complaint” and remand, or return, the case to Monterey County Superior Court. He attached an amended complaint that he had filed in state court. The defendants pointed out that the amended complaint still referred to federal laws and to the elements of First and Eighth Amendment claims. Harris responded that his claim was that A Carwithen negligently performed duties and caused mental injuries, making state court more appropriate.
Ruling
The court construed Harris’s withdrawal request and his stated intent to amend as a motion to amend. Under Federal Rule of Civil Procedure 15(a), a party may amend a pleading once as a matter of course before the relevant deadline when no responsive pleading or dispositive motion has been filed. Because no such filing had been made or was due, the court granted the motion to amend and deemed the complaint amended.
The court concluded that the amended complaint no longer contained federal claims. Because there was no longer a basis for federal subject-matter jurisdiction—the court’s authority to hear the case—the court remanded the action to Monterey County Superior Court. The defendants’ request to screen the complaint was denied as moot, meaning the court did not need to address that request after remanding the case. The order disposed of Docket Nos. 2 and 8.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.