Royal Canin U. S. A. v. Wullschleger

604 U.S. 22, 220 L. Ed. 2d 289, 145 S. Ct. 41
Supreme Court of the United States·Decided January 15, 2025·No. 23-677·Published·Cited by 304 cases

Opinions

Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus

ROYAL CANIN U. S. A., INC., ET AL. v. WULLSCHLEGER ET AL.

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT

No. 23–677. Argued October 7, 2024—Decided January 15, 2025 Respondent Anastasia Wullschleger sued petitioner Royal Canin U. S. A., Inc., in state court, alleging that Royal Canin had engaged in deceptive marketing practices. Her original complaint asserted claims based on both federal and state law. Royal Canin removed the case to federal court under 28 U. S. C. §1441(a). That removal was premised on Wullschleger’s federal claim, which gave rise to federal-question jurisdiction and also allowed the federal court to exercise supplemental jurisdiction over Wullschleger’s factually intertwined state claims. §§1331, 1367. But federal court is not where Wullschleger wanted the case to be resolved. So she amended her complaint, deleting every mention of federal law, and petitioned the District Court for a remand to state court. The District Court denied Wullschleger’s request, but the Eighth Circuit reversed. In the Eighth Circuit’s view, Wullschleger ’s amendment had eliminated any basis for federal-question jurisdiction. And without a federal question, the court concluded, there was no possibility of supplemental jurisdiction over Wullschleger ’s state-law claims. Held: 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. Pp. 6– 20. (a) Under the text of §1367, the supplemental-jurisdiction statute, a post-removal amendment to a complaint that eliminates any basis for federal-question jurisdiction also divests a federal court of supplemental jurisdiction over remaining state-law claims. Subsection (a) states that “in any civil action of which the district courts have original

jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy .” The statute thus confers supplemental jurisdiction over state-law claims sharing a sufficient factual relationship with the federal claims in a case. And in Rockwell Int’l Corp. v. United States, 549 U. S. 457, 473–474, this Court held that “when a plaintiff files a complaint in federal court and then voluntarily amends the complaint, courts look to the amended complaint to determine jurisdiction.” So under §1367(a), when the plaintiff in an original case amends her complaint to withdraw the federal claims, leaving only state claims behind, she divests the federal court of supplemental jurisdiction. And the result must be the same in a removed case, because nothing in §1367(a)’s text distinguishes between cases removed to federal court and cases originally filed there. The exclusion from §1367(a) of such post-amendment state-law claims is reflected in the text of §1367(c). Subsection (c) provides that a district court “may decline to exercise supplemental jurisdiction” over state-law claims covered by §1367(a)’s jurisdictional grant in three specific situations where the state-law claims overshadow the federal claims in a case. If §1367(a)’s grant of jurisdiction included the leftover state claims in an amended complaint, they too would have appeared on §1367(c)’s list: Even more than the claims addressed there, they are ill-suited to federal adjudication. That §1367(c) makes no mention of such claims demonstrates that §1367(a) does not extend to them. That result accords with Congress’s usual view of how amended pleadings can affect jurisdiction. On that view, apparent in varied federal statutes, an amendment can wipe the jurisdictional slate clean, giving rise to a new analysis with a different conclusion. E.g., §1653 (“[d]efective allegations of jurisdiction may be amended” so a case can come within a federal court’s jurisdiction); §1446(b)(3) (even “if the case stated by the initial pleading is not removable,” the defendant can remove the case after receiving “an amended pleading” establishing a basis for federal jurisdiction); §1332(d)(7) (similar). And just the same here: Section 1367 contemplates that when an amended complaint is filed, the jurisdictional basis for the suit is reviewed anew. Pp. 7–10. (b) That reading of §1367 also parallels a slew of other procedural rules linking jurisdiction to the amended, rather than initial, complaint . In deciding which substantive claims to bring against which defendants, a plaintiff can establish—or not—the basis for a federal court’s subject-matter jurisdiction. And her control over those matters extends beyond the time her first complaint is filed. If a plaintiff amends her complaint, the new pleading supersedes the old one and

can bring the suit either newly within or newly outside a federal court’s jurisdiction. Thus, as Rockwell explained, if “a plaintiff files a complaint in federal court and later voluntarily amends the complaint” to “withdraw[ ]” the allegations supporting federal jurisdiction, that amendment “will defeat jurisdiction” unless the withdrawn allegations were “replaced by others” giving the court adjudicatory power. 549 U. S., at 473–474. Rockwell’s rule has a host of variations in both original and removed federal cases. Adding federal claims can create original jurisdiction where it once was wanting. See, e.g., ConnectU LLC v. Zuckerberg, 522 F. 3d 82, 91. And an amendment can either destroy or create jurisdiction in an original diversity case. See Owen Equipment & Erection Co. v. Kroger, 437 U. S. 365, 374–377; Newman-Green, Inc. v. Alfonzo -Larrain, 490 U. S. 826, 832–833. Similarly, if removing a case was improper because the initial complaint did not contain a federal claim, the plaintiff’s later assertion of such a claim establishes jurisdiction going forward. See Pegram v. Herdrich, 530 U. S. 211, 215– 216, and n. 2. And by the same token, amending a complaint in a removed case to join a non-diverse party destroys diversity jurisdiction, and the federal court must remand the case to state court. See §1447(e). In removed and original cases alike, the rule that jurisdiction follows the operative pleading ensures that the case, as it will actually be litigated, merits a federal forum. Pp. 10–15. (c) Royal Canin contends that this Court has twice before reached the opposite conclusion—first, in Carnegie-Mellon Univ. v. Cohill, 484 U. S. 343, and next in Rockwell, in a footnote. But in each case, the relied-on passage is extraneous to the Court’s holding and reasoning, and so cannot bear the weight of Royal Canin’s argument. The footnote in Rockwell does state the rule Royal Canin propounds: “[W]hen a defendant removes a case to federal court based on the presence of a federal claim,” it says, “an amendment eliminating the original basis for federal jurisdiction generally does not defeat jurisdiction.” 549 U. S., at 474, n. 6. But Rockwell was an original federal case, not a removed one, so its drive-by assertion of a jurisdictional rule for removed cases was entirely outside the issue being decided. That dictum cannot overcome the Court’s analysis here or Rockwell’s own core insight that federal courts “look to the amended complaint to determine jurisdiction.” Id., at 474. Pp. 15–20. 75 F. 4th 918, affirmed.

KAGAN, J., delivered the opinion for a unanimous Court.

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Royal Canin U. S. A. v. Wullschleger, 604 U.S. 22, 220 L. Ed. 2d 289, 145 S. Ct. 41 (2025).

604 U.S. 22 (Royal Canin U. S. A. v. Wullschleger) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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