Royal Canin U.S.A. v. Wullschleger
In brief
After a plaintiff deletes every federal claim from a properly removed case, the remaining state-law case must return to state court.
- Where it stands
- Decided
Decided 9-0 · January 15, 2025 · Opinion by Justice Kagan
- What it’s about
- The Supreme Court ruled that when a plaintiff amends their complaint to remove all federal claims after a case has been moved to federal court, the federal court loses jurisdiction over the remaining state-law claims.
- Who it affects
- Plaintiffs whose cases are moved to federal court can return to state court by removing all federal claims from their complaint.
Summary: written with AI from the case record.
What it's about
The Court held that jurisdiction is determined by the amended complaint, meaning the case must be sent back to state court once the federal questions are gone.
The decision clarifies when federal courts may keep state-law claims after defendants remove a case from state court.
Question presented
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?
What the Court decided
Holding
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. 75 F. 4th 918, affirmed.
- Result
- Affirmed
The vote
From the opinions
“the federal court loses supplemental jurisdiction over the state claims, and the case must be remanded to state court.”
What's next
Lower federal courts must remand cases when plaintiffs amend their complaints to eliminate the federal claims supporting removal. The parties then continue litigating the remaining state-law claims in state court.
Why it matters
For example, a consumer bringing state-law claims against a company can pursue those claims in state court after dropping federal ones.
Documents
Docket activity
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More questions
- What did the Supreme Court rule in Royal Canin v. Wullschleger?
- The Court ruled that deleting all federal claims after removal leaves the federal court without authority over the remaining state-law claims. The case must return to state court.
- Who won Royal Canin v. Wullschleger?
- Anastasia Wullschleger and the other plaintiffs won. The Court affirmed the Eighth Circuit's decision requiring remand to state court.
- How does Royal Canin v. Wullschleger affect removed cases?
- A plaintiff may amend the complaint to remove every federal claim. Federal courts then must send the remaining state-law claims back to state court.
- Is the rule on remanding state-law claims still the law after Royal Canin v. Wullschleger?
- Yes. The Court unanimously said federal courts lose supplemental jurisdiction over remaining state-law claims after all federal claims are deleted.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.