Integranet Physician Resource v. Texas Independent Providers, No. 18-20659 (5th Cir. 2019)Annotate this Case
After IntegraNet filed suit against a former-employee owner in state court and the case was removed to federal court, IntegraNet then filed suit against the former-employee owner in state court for another claim. The district court consolidated the cases and sua sponte barred IntegraNet from filing another case against appellees without the judge's permission.
The Fifth Circuit held that the district court abused its discretion in exercising jurisdiction in light of Enochs v. Lampasas County, 641 F.3d 155, 161 (5th Cir. 2011), which held that courts are instructed to examine their jurisdiction at every stage of the litigation; consolidation was inappropriate, because the primary lawsuit lacked a basis for federal jurisdiction; and the lack of federal jurisdiction also rendered the pre-filing injunction improper. Accordingly, the court reversed the consolidation order, vacated the injunction, and remanded both claims with instructions to the district court to remand the Texas state law claims to the Texas state court from which the cases were removed.