Royal Canin U.S.A. v. Wullschleger
Decision
Opinion of the Court
Overview
Overview
Royal Canin U.S.A., Inc. v. Wullschleger held that when a plaintiff amends a complaint after removal to eliminate all federal claims, the federal district court loses subject matter jurisdiction over the remaining state law claims and must remand. The case arose from a class action challenging the marketing of prescription pet food, where the plaintiff's post-removal amendment stripped the only basis for federal question jurisdiction. The Court, unanimous in judgment, rejected the argument that removal jurisdiction could persist once the federal claims disappeared.
The Facts
Facts
Respondent Wullschleger filed a putative class action in Missouri state court against Royal Canin, alleging deceptive marketing of prescription pet food under both state law and federal statutes. Royal Canin removed the case to federal court under federal question jurisdiction. Wullschleger amended the complaint to drop all federal claims and moved to remand, arguing the court no longer had subject matter jurisdiction.
The Issue
Issue
Whether a federal court retains subject matter jurisdiction after the plaintiff amends a post-removal complaint to eliminate the federal claims that originally supported removal.
The Rules
Rule
When a plaintiff amends a complaint after removal to delete the federal claims that formed the basis for removal, the district court loses subject matter jurisdiction and must remand the case to state court. Jurisdiction is assessed on the operative pleading, not the original one.
The Application
Analysis
When Wullschleger amended the complaint after removal to eliminate all federal statutory claims, the operative pleading contained only state law allegations against Royal Canin for deceptive marketing of prescription pet food. The district court's jurisdiction hinged on whether the amended complaint retained a federal question, and under the governing rule, jurisdiction must be assessed based on the operative pleading rather than the original complaint filed in state court. Because no federal claims remained in the amended complaint, the federal court lost subject matter jurisdiction and was obligated to remand the case to Missouri state court where it originated.
The Conclusion
Conclusion
The Court reversed the Eighth Circuit. Because Wullschleger's amended complaint no longer contained any federal claims, the district court could not retain jurisdiction over the remaining state law claims under federal question jurisdiction. The case was remanded to state court.
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