Royal Canin U. S. A., Inc. et al. v. Wullschleger et al.
No. 23-677 · Decided January 15, 2025 · affirmed
Does a federal district court retain supplemental jurisdiction over state-law claims if a plaintiff amends her complaint to delete the federal-law claims that originally enabled the case's removal from state court? 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.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT · Argued October 7, 2024
Parties — Petitioner: ROYAL CANIN U. S. A., INC., et al. · Respondent: WULLSCHLEGER et al.
Vote & lineup9–0 (unanimous) on the judgment. Kagan delivered the opinion for a unanimous Court (9).
Who prevailed — The respondent prevailed on the issue of whether her case should be remanded to state court after she amended her complaint to remove all federal claims.
The question

Does a federal district court retain supplemental jurisdiction over state-law claims if a plaintiff amends her complaint to delete the federal-law claims that originally enabled the case's removal from state court? This question asks whether a post-removal amendment can divest a federal court of subject-matter jurisdiction. The Court must determine if the rule for cases originally filed in federal court applies equally to removed cases.

Petitioner's argument
  • Section 1367(a) provides broad supplemental jurisdiction over "all other claims" within a case or controversy unless Congress "expressly provided otherwise."
  • Congress has not expressly stated that an amendment deleting federal claims eliminates supplemental jurisdiction.
  • Precedent in *Carnegie-Mellon Univ. v. Cohill* and a footnote in *Rockwell Int'l Corp. v. United States* suggests that a federal court may retain jurisdiction even after the original basis for federal jurisdiction is eliminated via amendment.
Respondent's argument
  • An amended complaint supersedes the original pleading and becomes the operative document for determining subject-matter jurisdiction.
  • Once the federal-law claims are deleted, there is no longer a "federal question" to provide original jurisdiction under 28 U. S. C. § 1331.
  • Without an underlying claim within the court's original jurisdiction, supplemental jurisdiction under 28 U. S. C. § 1367 vanishes because there is nothing left to supplement.
The decision
  • The Court held that when a plaintiff amends her complaint to delete the federal-law claims that enabled removal, the federal court loses supplemental jurisdiction over any remaining state-law claims and must remand the case to state court.
  • Under 28 U. S. C. § 1367(a), supplemental jurisdiction is only available for claims "so related to claims in the action within such original jurisdiction that they form part of the same case or controversy."
  • Relying on *Rockwell Int'l Corp. v. United States*, the Court reasoned that courts must look to the amended complaint, not the original, to determine jurisdiction; thus, withdrawing federal allegations "will defeat jurisdiction" unless replaced by other jurisdictional claims.
  • The Court noted that 28 U. S. C. § 1367(a) contains no text distinguishing between cases originally filed in federal court and those removed from state court, meaning the *Rockwell* rule applies to both.
  • The Court found that 28 U. S. C. § 1367(c)—which lists reasons a court may decline supplemental jurisdiction—does not mention amendments deleting federal claims, implying such claims are not covered by the grant of jurisdiction in subsection (a) at all.
  • This result is consistent with other statutes where amendments "wipe the jurisdictional slate clean," including 28 U. S. C. § 1653, § 1446(b)(3), and § 1332(d)(7).
  • The Court observed that in removed diversity cases, adding a non-diverse party destroys jurisdiction under 28 U. S. C. § 1447(e), further demonstrating that jurisdiction follows the operative pleading.
  • The Court dismissed the reliance on *Carnegie-Mellon Univ. v. Cohill* and a footnote in *Rockwell*, characterizing them as "dictum" or "drive-by jurisdictional rulings" that lack precedential effect under the standards set in *Wilkins v. United States*, *Arbaugh v. Y & H Corp.*, and *Henderson v. Shinseki*.