context: . Only four published opinions have read section 1447(c) to authorize an award of fees or costs against plaintiffs. Three involved a removal that was, at the outset, improper, and thus they are not inconsistent with the conclusion we reach today.
citation_a.signal: see
citation_a.parenthetical: removal improper because plaintiff's only federal claim was, by her own admission, frivolous
citation_a.sentence: See Vaughan, 227 F. 364 (removal based on diversity improper because plaintiff mispled residency in complaint); Duarte v. Donnelley, 266 F.Supp. 380, 384 (D.Haw.1967) (removal improper because amount in controversy was below jurisdictional limit); Barraclough v. ADP Automotive Claims Servs., Inc., 818 F.Supp. 1310 (N.D.Cal.1993) (removal improper because plaintiff's only federal claim was, by her own admission, frivolous).
citation_b.signal: but see
citation_b.parenthetical: remand forced by plaintiff's subsequent amendment of complaint to join a local defendant
citation_b.sentence: But see Clark v. Safeway Stores, Inc., 117 F.Supp. 583 (W.D.Mo.1953) (remand forced by plaintiff's subsequent amendment of complaint to join a local defendant).