Royal Canin U. S. A. v. Wullschleger
604 U. S. ____ (2025) (2025)
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Rule of Law:
When a plaintiff amends a complaint post-removal to eliminate all federal-law claims that provided the basis for removal, the federal court loses supplemental jurisdiction over the remaining state-law claims and must remand the case to state court.
Facts:
- Anastasia Wullschleger purchased prescription dog food manufactured by Royal Canin U. S. A., Inc.
- Wullschleger believed the food contained medication that was not present in over-the-counter dog food products.
- She later discovered that the prescription food did not contain any medication.
- Wullschleger alleged that Royal Canin required a prescription for the food not for medical reasons, but as a deceptive marketing practice to justify charging a premium price.
Procedural Posture:
- Anastasia Wullschleger sued Royal Canin U. S. A., Inc. in a Missouri state trial court, asserting claims based on state law and the federal Food, Drug, and Cosmetic Act (FDCA).
- Royal Canin removed the case to the U.S. District Court, citing federal-question jurisdiction due to the FDCA claims.
- In the District Court, Wullschleger amended her complaint to remove all federal law claims, leaving only state-law claims.
- Wullschleger then moved to remand the case to state court, but the District Court denied the request.
- Following the denial of remand, the District Court dismissed the amended complaint on the merits.
- Wullschleger appealed to the U.S. Court of Appeals for the Eighth Circuit, which reversed the District Court's decision and held the case must be remanded to state court.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does a federal district court retain supplemental jurisdiction over state-law claims when a plaintiff, after the case has been removed from state court, amends the complaint to eliminate all federal-law claims?
Opinions:
Majority - Justice Kagan
No. When an amendment excises the federal-law claims that enabled removal, the federal court loses its supplemental jurisdiction over the related state-law claims. The court's jurisdiction is determined by the operative pleading, which is the amended complaint. According to 28 U.S.C. § 1367(a), supplemental jurisdiction exists over claims that are 'so related to claims in the action within such original jurisdiction.' Once the claims conferring original jurisdiction are removed from the complaint, there is nothing for the state claims to be supplemental to. The Court extends the rule from Rockwell Int’l Corp. v. United States, which held that in cases originally filed in federal court, an amended complaint that removes federal claims defeats jurisdiction. Since the text of § 1367 draws no distinction between original and removed cases, the same principle must apply here. The amended complaint supersedes the original, and if it contains no basis for federal jurisdiction, the case must be remanded.
Analysis:
This decision resolves a circuit split and establishes a clear, uniform rule that jurisdiction is determined by the operative pleading, not the complaint as it existed at the time of removal. It significantly strengthens the plaintiff's position as the 'master of the complaint,' affirming their ability to dictate the forum by strategically amending claims. The ruling effectively allows plaintiffs to force a remand to their preferred state court by dropping federal claims, thereby limiting a defendant's ability to keep a case in a federal forum against the plaintiff's wishes. This clarifies the scope of 28 U.S.C. § 1367 and dismisses prior dicta suggesting a different rule for removed cases.
