SO, I PROCEED ON SEEKING REMAND TO STATE COURT MY CASE AGAINST THE CITY OF BROWNSVILLE

First a correction:  I initially cites § 1441 as a basis for remand based on the fact the case is nearly 100% state law.  Well § 1441 was amended taking out the language for "predominantly state law."  

But the law did not really change.  § 1367 is actually stronger and in particular to the fact the Texas Supreme Court is poised to rule on the state law issues. 

It is extraordinary that any attorney would remove to federal court a case poised to be decided by the Texas Supreme Court on state law issues and thereby create a possible 5-year delay.

The Texas Supreme Court is poised to rule on its application of the Comment in Canon 4 concerning strongly held religious beliefs on marriage. The Texas Supreme Court has sole jurisdiction over the matter and can resolve it forthwith.  If the case is successfully removed, a separate lawsuit will be filed in Austin. 

The motion to remand would already be filed, except the statutory rules, Southern District of Texas rules and Judge Orlando Olvera rules are a burden.  To the seasoned lawyer in federal court, it is probably pretty simple and not burdensome.  But as a first-time filer under the new rules, it is very burdensome.

If I can file directly with the clerk, I will.

But I own the issue.  The question is getting it before Judge Olvera.