In Warthman v. Genoa Twp. Bd. of Trustees (C.A.6, 2008), 549 F.3d 1055, the plaintiff filed suit in state court alleging the defendants violated the Ohio Open Meeting Law and her due process rights. The defendants removed the matter to federal court, and the plaintiff sought a remand back to state court. In concluding the complaint asserted only state causes of action, the court noted that while the facts pled by the plaintiff might have supported a due process claim, section 1983 was not mentioned anywhere in the plaintiff's complaint. The court elaborated as follows: Some complaints, however, particularly those filed by pro se plaintiffs, have asserted claims for relief under the U.S. Constitution directly. District courts have on occasion interpreted such claims as 1983 actions. See, e.g., Jordan v. Murphy, No. 99-3489, 2000 U.S. App (6th Cir. Feb. 2, 2000) (unpublished) (construing a complaint that referenced the Fourth Amendment as a 1983 claim because "this circuit does not recognize direct constitutional claims against local officials and municipalities" (citing Thomas v. Shipka, 818 F.2d 496, at 499)). But the omission of a reference to 1983 in a carefully drafted complaint filed by a plaintiff represented by counsel should have provided the Township with notice that Warthman's reference to the Due Process Clause was not intended to raise a federal cause of action. Warthman took great care to assert only state-law claims in her complaint, a choice that she was fully entitled to make even if it meant foregoing an available federal cause of action. See Alexander v. Elec. Data Sys. Corp., 13 F.3d 940, 943 (6th Cir. 1994) ("The well-pleaded complaint rule generally provides that the plaintiff is the master of his complaint, and the fact that the wrong asserted could be addressed under either state or federal law does not ordinarily diminish the plaintiff's right to choose a state law cause of action."). She explicitly alleged a violation of only the Ohio Open Meetings Law in Count One, and clarified any ambiguity about her common law estoppel claim in Count Two by asking the court to declare that she "had a right to a name clearing hearing which is the predicate for her hearing under R.C. 121.22(G)(1)." Warthman's complaint was not sloppily drafted. It neatly laid out two state-law causes of action and did not invite the Township--as a less careful complaint might have done--to latch onto the constitutional reference and imply a federal claim where none was stated. Warthman's freedom to choose state law in this manner would be significantly undermined by a rule that granted defendants the freedom to safely second guess a plaintiff's decision and remove to federal court on the basis of claims that could have been pled, but were not. See Alexander, 13 F.3d at 943. Id. at 1062-63.