What is the effect of the Court of Appeal's decision to remand the state claims?

Remanding the state claims is only one step beyond bifurcation of the trial which we so readily leave to the discretion of the trial court. See, e.g., Hirst v. Gertzen, 676 F.2d 1252, 1261 (9th Cir.1982) (bifurcation to avoid unnecessary jury confusion is within the sound discretion of the trial court). It may be that the effect of today's ruling will be less damaging than I fear because the district courts can achieve the goals of judicial economy, convenience, and fairness to litigants by bifurcation of the state claims when necessary.