In Carnegie Melon Univ. v. Cohill, 484 U.S. 343 , 108 S. Ct. 614 , 98 L. Ed. 2d 720 (1988), the Court addressed the issue of "whether a federal district court has discretion under the doctrine of pendent jurisdiction to remand a properly removed case to state court when all federal-law claims in the action have been eliminated and only pendent state-law claims remain." Carnegie Mellon, 484 U.S. at 345, 108 S.Ct. at 616. The Court concluded that a district court has discretion to remand pendent claims to state court when doing so furthers the principles of judicial economy, convenience, fairness, and comity. Carnegie Mellon, 484 U.S. at 357, 108 S.Ct. at 622-23. The Court decided on principles of pendent jurisdiction because the federal claims had been eliminated and only state law claims remained,3 the Court explained that "28 U.S.C. sections 1441(c) and 1447(c) ... do not apply to cases over which a federal court has pendent jurisdiction. Thus, the remand authority conferred by the removal statute and the remand authority conferred by the doctrine of pendent jurisdiction overlap not at all." Id. at 355 n. 11, 108 S.Ct. at 621 n. 11. In Carnegie-Mellon, the "single federal-law claim in the action was eliminated at an early stage of the litigation" giving the district court "a powerful reason to choose not to continue to exercise jurisdiction." 484 U.S. at 351, 108 S.Ct. at 619. The pivotal issue in Carnegie-Mellon was whether the district court should relinquish jurisdiction by dismissing the case, consisting of the pendent state law claims, without prejudice or by remanding it to the state court. Id. The Court concluded that remand was preferable to dismissal, which might preclude a plaintiff from litigating claims because of the expiration of a state statute of limitations. Id. at 351-53, 108 S.Ct. at 619-20. In Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343, 108 S.Ct. 614, 98 L.Ed.2d 720 (1988), the Supreme Court held that district courts have discretion to remand "a removed case involving pendent claims upon a proper determination that retaining jurisdiction over the case would be inappropriate." 484 U.S. at 357, 108 S.Ct. 614. The Court reasoned that (1) the animating principle underlying the flexible doctrine of pendent jurisdiction in United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed.2d 218 (1966), supports giving district courts discretion not only to dismiss but also to remand; and (2) the removal statute does "not address specifically any aspect of a district court's power to dispose of pendent state-law claims after removal." Cohill, 484 U.S. at 348-55, 108 S.Ct. 614. In doing so, the Court stated in a footnote that "Section 1447(c), as the dissent recognizes, does not apply to cases over which a federal court has pendent jurisdiction. Thus, the remand authority conferred by the removal statute and the remand authority conferred by the doctrine of pendent jurisdiction overlap not at all." 484 U.S. at 355 n. 11, 108 S.Ct. 614. In Carnegie-Mellon University v. Cohill, 484 U.S. 343, 108 S.Ct. 614, 98 L.Ed.2d 720 (1988), the Supreme Court established the right of a district court to remand, as opposed to only dismiss, a pendent claim: A district court has discretion to remand to state court a removed case involving pendent claims upon a proper determination that retaining jurisdiction over the case would be inappropriate. The discretion to remand enables district courts to deal with cases involving pendent claims in the manner that best serves the principles of economy, convenience, fairness, and comity which underlie the pendent jurisdiction doctrine. Carnegie-Mellon, 484 U.S. at 357, 108 S.Ct. 614. In Carnegie-Mellon University v. Cohill, U.S. 108 S.Ct. 614, 98 L.Ed.2d 720 (1988), the Court held that "a district court has discretion to remand to state court a removed case involving pendent claims upon a proper determination that retaining jurisdiction over the case would be inappropriate. The discretion to remand enables district courts to deal with cases involving pendent claims in the manner that best serves the principles of economy, convenience, fairness and comity which underlie the pendent jurisdiction doctrine." 108 S.Ct. at 622.