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Royal Canin U.S.A., Inc. v. Wullschleger

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Supreme Court of the United States
Royal Canin U.S.A., Inc. v. Wullschleger
Term: 2024
Important Dates
Argued: October 7, 2024
Decided: January 15, 2025
Outcome
affirmed
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson

Royal Canin U.S.A., Inc. v. Wullschleger is a case that was decided by the Supreme Court of the United States on January 15, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on October 7, 2024.

In a 9-0 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eighth Circuit. The Court held that once Wullschleger amended her complaint to remove all federal law claims, the suit became a state case.[1]

HIGHLIGHTS
  • The issue: The case concerned jurisdiction in a case with state court claims and federal court claims under 28 U.S.C. § 1331, which states that U.S. district courts hold original jurisdiction over all civil lawsuits under federal law and 28 U.S. Code § 1441 - Removal of civil actions, which governs such lawsuits brought in state court. Click here to learn more about the case's background.
  • The questions presented: "This Petition presents two separate but related questions concerning the ability of a plaintiff, in an action properly removed to federal court pursuant to 28 U.S.C. § 1441(a) on the basis of federal-question jurisdiction under 28 U.S.C. § 1331, to compel a remand to state court by amending the complaint to omit federal questions: 1. Whether such a post-removal amendment of the complaint defeats federal question subject-matter jurisdiction. 2. Whether such a post-removal amendment of the complaint precludes a district court from exercising supplemental jurisdiction over the plaintiffs remaining state-law claims pursuant to 28 U.S.C. § 1367."[2]
  • The outcome: In a 9-0 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eighth Circuit, holding that once Wullschleger amended her complaint to remove all federal law claims, the United States District Court for the Western District of Missouri no longer had supplemental jurisdiction over the state claims.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Eighth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Royal Canin U.S.A., Inc., et al.
      • Legal counsel: Christopher M. Curran (White & Case LLP)
    • Respondent: Anastasia Wullschleger, et al.
      • Legal counsel: Ashley Conrad Keller (Keller Postman LLC), James Patrick Frickleton (Bartimus, Frickleton, Robertson, Rader, PC)


    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]

    “

    Anastasia Wullschleger filed a class-action complaint in Missouri state court against Royal Canin and Nestle Purina, alleging that their requirement for a prescription for specialized dog food was misleading and led to higher prices. The defendants removed the case to federal court, which remanded it back to state court, and then they appealed to the U.S. Court of Appeals for the Eighth Circuit, which determined that the antitrust and unjust-enrichment claims raised substantial federal issues and belonged in federal court. Upon returning to the district court, Wullschleger amended her complaint to remove references to federal law, dropped the antitrust and unjust-enrichment claims, and added a civil-conspiracy claim. Despite these changes, the district court exercised federal-question jurisdiction and ultimately granted the manufacturers’ motion to dismiss, leading to a second appeal. Reviewing the case de novo, the Eighth Circuit concluded that amending a complaint to eliminate the only federal questions destroys subject-matter jurisdiction and thus returned the case to state court.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ This Petition presents two separate but related questions concerning the ability of a plaintiff, in an action properly removed to federal court pursuant to 28 U.S.C. § 1441(a) on the basis of federal-question jurisdiction under 28 U.S.C. § 1331, to compel a remand to state court by amending the complaint to omit federal questions:
    1. Whether such a post-removal amendment of the complaint defeats federal question subject-matter jurisdiction.
    2. Whether such a post-removal amendment of the complaint precludes a district court from exercising supplemental jurisdiction over the plaintiffs remaining state-law claims pursuant to 28 U.S.C. § 1367.[5]
    		 ”

    Oral argument

    The U.S. Supreme Court heard oral argument on October 7, 2024.

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 9-0 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eighth Circuit. The Court held that once Wullschleger amended her complaint to remove all federal law claims, the jurisdiction also changed; the United States District Court for the Western District of Missouri no longer had supplemental jurisdiction over the state claims. The suit became a state case. Justice Elena Kagan delivered the majority opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    “

    For those reasons, the District Court here should have remanded Wullschleger’s suit to state court. The earliest version of that suit contained federal-law claims and therefore was properly removed to federal court. The additional state-law claims were sufficiently related to the federal ones to come within that court’s supplemental jurisdiction. But when Wullschleger amended her complaint, the jurisdictional analysis also changed. Her deletion of all federal claims deprived the District Court of federal-question jurisdiction. And once that was gone, the court’s supplemental jurisdiction over the state claims dissolved too. Wullschleger had reconfigured her suit to make it only about state law. And so the suit became one for a state court.

    We accordingly affirm the judgment of the Court of Appeals for the Eighth Circuit. [5]

    		”
    —Justice Elena Kagan

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 U.S. Supreme Court, "Royal Canin U.S.A., Inc. v. Wullschleger," January 15, 2025
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-677 ROYAL CANIN U.S.A., INC. V. WULLSCHLEGER," accessed April 30, 2024
    3. ↑ Supreme Court of the United States, "No. 23-677," accessed August 7, 2024
    4. ↑ Oyez, ""Royal Canin U.S.A., Inc. v. Wullschleger,"" accessed August 7, 2024
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ U.S. Court of Appeals for the Eighth Circuit, Wullschleger v. Royal Canin U.S.A., Inc., decided July 31, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 7, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 7, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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