MARTIN v. FRANKLIN CAPITAL CORP.

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Case Basics
Docket No. 
04-1140
Petitioner 
Gerald T. Martin, et ux.
Respondent 
Franklin Capital Corporation, et al.
Advocates
(argued the cause for Respondents)
(argued the cause for Petitioners)
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Facts of the Case 

No. In a unanimous decision authored by Justice Anthony Kennedy, the Court rejected the Ninth Circuit's reasoning. The Court ruled that the state court did not act unreasonably when it determined that the prosecutor's race-neutral explanations were credible. Although there might have been some evidence that could be interpreted as undermining the prosecutor's credibility, the trial court was in a better position to determine those facts. The Court faulted the Ninth Circuit for substituting "its own debatable interpretation of the record" for the trial courts findings, and for "misapplying settled rules that limit [the Circuit Court's] role and authority."

Question 

What standard should federal courts use when determining whether to award attorney's fees after an improperly removed case is remanded to state court?

Conclusion 
Decision: 9 votes for Franklin Capital Corp., 0 vote(s) against
Legal provision: 28 U.S.C. 1447

In a unanimous decision authored by Chief Justice John Roberts, the Court ruled that "absent unusual circumstances, attorney's fees should not be awarded when the removing party has an objectively reasonable basis for removal." The Court admitted that Section 1447 is unclear on when attorney's fees should be added. The Court's reading of the statute detected no strong textual bias for or against awarding fees. Considering the likely motives of Congress, the Court ruled that attorney's fees should only be awarded when a party sought removal without an objectively reasonable basis. Since Franklin had such a basis, Martin was not entitled to any fees.

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MARTIN v. FRANKLIN CAPITAL CORP.. The Oyez Project at IIT Chicago-Kent College of Law. 20 June 2014. <http://www.oyez.org/cases/2000-2009/2005/2005_04_1140>.
MARTIN v. FRANKLIN CAPITAL CORP., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2005/2005_04_1140 (last visited June 20, 2014).
"MARTIN v. FRANKLIN CAPITAL CORP.," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 20, 2014, http://www.oyez.org/cases/2000-2009/2005/2005_04_1140.