The Hain Celestial Group, Inc., et al., Petitioners v. Sarah Palmquist, Individually and as Next Friend of E.P., a Minor, et al.

The Supreme Court unanimously said a federal court's final judgment cannot stand if the case lacked complete diversity (all plaintiffs from different states than all defendants) when it was removed from state court. The Court also said a judge cannot fix that problem by wrongly dismissing a nondiverse party under Rule 21.

The Court ruled 9-0, with Justice Sotomayor writing for the Court.

Majority

Sotomayor

Roberts

Thomas

Alito

Kagan

Gorsuch

Kavanaugh

Barrett

Jackson

“A federal court cannot create jurisdiction over a lawsuit through its own erroneous ruling.”

The decision limits when companies can keep cases in federal court after removing them from state court. In product liability suits, for example, plaintiffs can keep their chosen state forum if a valid claim includes a local defendant.

Lower courts must apply this rule when reviewing removed cases with disputed party citizenship. Parties in similar cases may seek remand to state court or challenge federal judgments entered after an improper removal.

The dispute was whether a federal case could stay in federal court after removal even though complete diversity was missing at the start.

Companies and consumers in product liability cases are affected because improper removal can now send more cases back to state court.

Lower courts must follow this rule in future removal disputes, and litigants may ask to return similar cases to state court.