Royal Canin U. S. A. v. Wullschleger
604 U.S. 22
SCOTUS2025Background
- Anastasia Wullschleger sued Royal Canin U.S.A., Inc. in Missouri state court, alleging deceptive marketing of prescription dog food, initially asserting both state and federal claims (including under the FDCA).
- Royal Canin removed the case to federal court on the basis of federal-question jurisdiction due to the FDCA-related allegations, bringing related state-law claims under supplemental jurisdiction.
- Wullschleger amended her complaint to remove any reference to federal law, leaving only state-law claims, and sought remand to state court.
- The district court denied remand, but the Eighth Circuit reversed, holding that the amendment eliminated federal jurisdiction, requiring remand.
- Royal Canin sought Supreme Court review, citing a circuit split on whether post-removal amendments eliminating federal claims require a remand to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does removing federal claims from a complaint after removal to federal court require the court to remand the case to state court? | Wullschleger: Once the complaint drops all federal-law claims, federal courts lose subject matter and supplemental jurisdiction over the remaining state-law claims, compelling remand. | Royal Canin: The existence of subject matter jurisdiction is determined at the time of removal, so post-removal amendments do not defeat federal jurisdiction over the now state-only case. | Remand required: Once all federal claims are removed, federal courts lose supplemental jurisdiction over the state-law claims and must remand. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (U.S. 1906) (syllabus is not part of the opinion)
- Mine Workers v. Gibbs, 383 U.S. 715 (U.S. 1966) (supplemental jurisdiction over state-law claims sharing a nucleus of operative fact with federal claims)
- Rockwell Int’l Corp. v. United States, 549 U.S. 457 (U.S. 2007) (jurisdiction is determined by the facts and claims in the amended complaint)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (U.S. 1988) (pre-§1367 discretion of district courts to remand after dismissal of federal claims, with dictum on discretion to retain jurisdiction)
- Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375 (U.S. 1994) (federal courts are courts of limited jurisdiction)