Royal Canin U.S.A. v. Wullschleger

In this case, the court considered this issue: Can a plaintiff whose state-court lawsuit has been removed by the defendants to federal court seek to have the case sent back to state court by amending the complaint to omit all references to federal law?

The case was decided on January 15, 2025.

The Supreme Court held that when a plaintiff amends her complaint to delete the federal-law claims that enabled removal to federal court, leaving only state-law claims behind, the federal court loses supplemental jurisdiction over the state claims, and the case must be remanded to state court. Justice Elena Kagan authored the unanimous opinion of the Court.

Federal jurisdiction is based on the operative complaint, which means that when a plaintiff amends their complaint, courts look to that amended version to determine jurisdiction. Federal courts can exercise supplemental jurisdiction over state law claims when they are part of the same case as federal claims. However, this supplemental jurisdiction flows from the existence of federal jurisdiction; when federal claims are eliminated, there is no longer any basis for supplemental jurisdiction over the state law claims.

This principle applies equally to cases that were originally filed in federal court and those that were removed from state court, as the supplemental jurisdiction statute (28 U-S-C § 1367) makes no distinction between the two situations. When Wullschleger amended her complaint to remove all federal claims after removal, the federal court lost its basis for federal question jurisdiction. Without any federal claims remaining, the court also lost supplemental jurisdiction over the state law claims. Therefore, the entire case had to be remanded to state court.

The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.