Royal Canin U. S. A. v. Wullschleger
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Royal Canin U. S. A. v. Wullschleger and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Royal Canin U. S. A. v. Wullschleger.
In Royal Canin U.S.A., Inc. v. Wullschleger, the Supreme Court addressed whether a federal court retains supplemental jurisdiction over state-law claims when a plaintiff amends a complaint to remove federal claims that initially justified removal to federal court. The case originated when Anastasia Wullschleger sued Royal Canin for deceptive marketing practices, initially including federal claims. After removal to federal court, Wullschleger amended her complaint to exclude federal claims, prompting a jurisdictional dispute. The Eighth Circuit ruled that the federal court lost jurisdiction, a decision affirmed by the Supreme Court.
Holding
The single most important “bottom line” of what the Court decided in Royal Canin U. S. A. v. Wullschleger.
The Court held that when a plaintiff amends a complaint to remove federal claims, the federal court loses supplemental jurisdiction over remaining state-law claims, necessitating remand to state court.
Constitutional Concepts
These are the Constitution-related themes that appear in Royal Canin U. S. A. v. Wullschleger. Click a concept to see other cases that involve the same idea.
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Why Federalism is relevant to Royal Canin U. S. A. v. Wullschleger
The case involves the division of power between federal and state courts, specifically regarding jurisdiction and the ability to remand cases to state court.
Syllabus excerpt (verbatim)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.
Key Quotes
Short excerpts from the syllabus in Royal Canin U. S. A. v. Wullschleger that support the summary and concepts above.
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.
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.
Rockwell's rule has a host of variations in both original and removed federal cases.