Royal Canin U. S. A. v. Wullschleger

Background

Anastasia Wullschleger, a Missouri consumer, sued Royal Canin, a company that sells prescription-only dog food, alleging deceptive marketing. Her original state-court complaint included both state-law claims and claims invoking the Federal Food, Drug, and Cosmetic Act. Royal Canin removed the case to federal court based on the federal claim, which also allowed the federal court to hear the related state claims. Wullschleger then amended her complaint to delete every federal-law claim and asked the district court to return the case to state court; the district court denied that request and the Eighth Circuit ordered remand.

Reasoning

The Court considered whether a plaintiff’s post-removal amendment that eliminates the federal claims bars a federal court from keeping the related state claims. The unanimous opinion, written by Justice Kagan, held that it does. The Court relied on the text of the supplemental-jurisdiction statute, which ties federal authority over state claims to the existence of an original federal claim, and on the long-standing rule that courts look to the amended, operative complaint to determine jurisdiction. The Court rejected arguments relying on earlier decisions’ passing language and explained that nothing in the statute treats removed cases differently.

Real world impact

Because the amended complaint becomes the operative pleading, a plaintiff who strips out the federal claims after removal can force a remand: the federal court loses supplemental jurisdiction and must return the remaining state-law suit to state court. The decision resolves a disagreement among federal appeals courts about post-removal amendments and clarifies how courts will handle similar procedural changes going forward.