Royal Canin U. S. A. v. Wullschleger
604 U. S. ____ (2025) (2025)
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Rule of Law:
When a plaintiff amends a removed complaint to delete the federal-law claims that enabled removal, leaving only state-law claims, the federal court loses supplemental jurisdiction over the remaining state claims and must remand the case to state court.
Facts:
- Royal Canin U. S. A., Inc., manufactures a brand of dog food that is sold at a premium price and requires a veterinarian's prescription.
- Anastasia Wullschleger purchased Royal Canin dog food, believing it contained medication not found in off-the-shelf products.
- Wullschleger later learned that the Royal Canin dog food did not contain medication.
- Wullschleger filed an original complaint in Missouri state court, alleging that Royal Canin engaged in deceptive marketing practices by selling ordinary dog food with a prescription requirement solely to trick consumers into paying a higher price.
- Wullschleger's original complaint asserted claims under the Missouri Merchandising Practices Act, state antitrust law, and alleged violations of the Federal Food, Drug, and Cosmetic Act (FDCA).
- Wullschleger subsequently amended her complaint to delete all mention of the FDCA allegations, leaving only her state-law claims.
Procedural Posture:
- Anastasia Wullschleger filed her original complaint in Missouri state court, asserting both federal (FDCA) and state-law claims against Royal Canin U. S. A., Inc.
- Royal Canin removed the case to federal District Court, based on federal-question jurisdiction arising from the FDCA claims.
- Wullschleger amended her complaint in the District Court, deleting all federal-law claims and leaving only state-law claims.
- Wullschleger petitioned the District Court for a remand of the case to state court.
- The District Court denied Wullschleger’s request to remand.
- After the District Court dismissed Wullschleger's amended complaint on the merits, Wullschleger, as appellant, appealed the denial of remand to the U.S. Court of Appeals for the Eighth Circuit.
- The U.S. Court of Appeals for the Eighth Circuit reversed the District Court's decision and ordered a remand to state court.
- Royal Canin U. S. A., Inc., as petitioner, sought certiorari from the Supreme Court of the United States.
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Issue:
Does a federal court retain supplemental jurisdiction over state-law claims, and thus the ability to adjudicate the case, when a plaintiff amends a complaint after removal to eliminate all federal-law claims?
Opinions:
Majority - Kagan, J.
No, a federal court may not adjudicate a case after a plaintiff amends a removed complaint to delete all federal-law claims, as the court loses supplemental jurisdiction over the remaining state-law claims. Federal courts are courts of limited jurisdiction, authorized by Article III of the Constitution and statutes like 28 U.S.C. §1331 (federal-question jurisdiction) and §1367 (supplemental jurisdiction). Section 1367(a) grants supplemental jurisdiction over state-law claims that are sufficiently related to claims within the court's original jurisdiction, but it makes no distinction between cases originally filed in federal court and those removed there. The Court's decision in Rockwell Int’l Corp. v. United States (2007) established that in original federal cases, when a plaintiff voluntarily amends a complaint to withdraw federal claims, courts look to the amended complaint to determine jurisdiction, and the court loses adjudicatory power over the remaining state-law claims. Given that §1367(a) draws no distinction between original and removed cases, the same rule must apply to removed cases: an amendment excising federal claims divests the federal court of supplemental jurisdiction. This is further supported by §1367(c), which lists discretionary grounds to decline supplemental jurisdiction; the absence of post-amendment state-law claims from this list suggests §1367(a) does not extend to them once the federal anchor is gone. The Court notes that this outcome aligns with Congress's usual view that amended pleadings can alter jurisdiction, effectively wiping the jurisdictional slate clean. The principle that the plaintiff is the 'master of the complaint' and that an amended complaint 'supersedes' the old one means that jurisdiction follows the operative pleading. The Court rejects Royal Canin's arguments based on Carnegie-Mellon Univ. v. Cohill (1988) and a footnote in Rockwell, deeming the relevant passages in both cases to be gratuitous dictum that neither analyzed the jurisdictional question at issue nor controls the present analysis based on §1367 and Rockwell's core holding. Therefore, when a plaintiff removes all federal-law claims via amendment, federal-question jurisdiction dissolves, and supplemental jurisdiction over the residual state claims disappears, requiring remand to state court.
Analysis:
This decision significantly clarifies the scope of federal supplemental jurisdiction in removed cases, particularly regarding the impact of post-removal amendments. By affirming that jurisdiction is determined by the operative, amended complaint—even if that amendment eliminates the original basis for federal jurisdiction—the Court reinforces the limited nature of federal court authority. The ruling resolves a circuit split, providing a uniform rule for district courts and potentially streamlining litigation by requiring remand when a plaintiff genuinely wishes to pursue only state-law claims. This case empowers plaintiffs as 'masters of their complaint' to control the forum of their litigation, even after removal, by ensuring that federal courts do not retain jurisdiction over purely state-law matters without a federal hook.
