On January 15, 2025, the Supreme Court of the United States issued a unanimous decision in Royal Canin U.S.A., Inc. v. Wullschleger, No. 23–677, holding that when a case alleging both state and federal claims is removed to federal court based on federal-question jurisdiction, and the plaintiff later amends its complaint to eliminate any federal question, the federal court is divested of supplemental jurisdiction over the state-law claims and the matter must be remanded to state court.
The plaintiff filed suit in Missouri state court alleging claims under the Missouri Merchandising Practices Act, state antitrust law, as well as violations of the Federal Food, Drug, and Cosmetic Act (FDCA). The defendant then removed the case to federal court based on federal-question jurisdiction, which in turn allowed the court to exercise supplemental jurisdiction over the plaintiff’s factually intertwined state-law claims.
In response, the plaintiff amended the complaint to eliminate all references to the FDCA, and moved to remand to state court. The federal district court denied the plaintiff’s motion, but the Eighth Circuit Court of Appeals reversed, holding that because the plaintiff no longer asserted a federal claim, the court no longer had federal-question jurisdiction. And without a federal question, which is what originally enabled the defendant to remove to federal court, the court could no longer exercise supplemental jurisdiction over the plaintiff’s remaining state-law claims.
The Supreme Court affirmed. The Court held that federal jurisdiction depends on the allegations in the operative pleading, and where an amended complaint eliminates any federal claims in a case removed based on federal-question jurisdiction, a federal court cannot exercise supplemental jurisdiction over the state-law claims that are left. The Court observed that the plaintiff is the master of the complaint and may decide which claims are brought, and against which parties, and therefore whether or not there is a basis on which a federal court may exercise its subject-matter jurisdiction.
Justice Kagan delivered the opinion for a unanimous Court.
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