State of Minnesota v. GoodLeap LLC, 0:24-cv-01181

The State of Minnesota filed a complaint in state court against GoodLeap LLC, Sunlight Financial LLC, Solar Mosaic LLC, and Dividend Solar Finance LLC, alleging violations of several Minnesota consumer protection laws.
Defendants Dividend and Sunlight Financial removed the case to federal court, arguing that the usury claim against Dividend/Fifth Third Bank raised a federal question due to complete preemption by the National Bank Act (NBA).
The federal court initially denied remand, finding federal jurisdiction based on preemption of the usury claim by the NBA.
The State amended its complaint to remove the usury claim after the court’s initial ruling, explicitly intending to eliminate the basis for federal jurisdiction.
The State then renewed its motion to remand the case to state court, arguing that only state law claims remained.
The Supreme Court decided Royal Canin, clarifying that federal courts lose supplemental jurisdiction when all federal claims are removed post-removal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal jurisdiction exists after usury claim removed	Amended complaint contains only state claims	Federal jurisdiction should be retained until SCOTUS decision in Royal Canin	Federal court lacks jurisdiction after amendment
Effect of Royal Canin Supreme Court decision	Case must be remanded based on Royal Canin	No opposition if Royal Canin affirmed	Royal Canin requires remand to state court
Whether supplemental jurisdiction applies to state claims	No jurisdiction over state claims alone	No remaining argument after Royal Canin	No supplemental jurisdiction; remand required
Ratification of amended complaint as basis for jurisdiction	Jurisdiction depends on the current complaint	Court must review amended pleading for jurisdiction	Must judge based on amended complaint

Royal Canin U.S.A., Inc. v. Wullschleger, 75 F.4th 918 (8th Cir. 2023) (removal jurisdiction lost when federal claims are eliminated by amendment; Supreme Court affirmed)
Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, 548 U.S. 308 (2005) (sets forth standard for federal-question jurisdiction under state law claims)