In a significant win for state court jurisdiction, Ward and Smith, alongside our partner firms, including Keller Postman (Chicago), Pope McGlamry (Atlanta), Walkup Melodia (San Francisco), Forde & O'Meara (Chicago), Shulman Buske (Minneapolis), and Bartimus Frickleton (Kansas City), secured a 9-0 favorable decision from the U.S. Supreme Court.
The ruling, delivered on January 15, 2025, in Royal Canin U.S.A., Inc. v. Wullschleger, affirms that federal courts lose supplemental jurisdiction over state-law claims when a plaintiff amends their complaint to remove federal-law claims after removal to federal court.
The case centered on allegations of deceptive marketing by Royal Canin, a company selling prescription dog food. The product was marketed as requiring a veterinarian's prescription, which led consumers to believe it contained specialized or medicinal ingredients unavailable in standard dog food.
Royal Canin removed the case to federal court, citing federal-question jurisdiction due to the inclusion of federal claims alongside state ones. However, the plaintiff amended the complaint to eliminate any arguably federal claims, leaving only state-law issues. This move triggered a pivotal legal debate about whether federal courts retain jurisdiction over remaining state claims when the federal claims used to justify removal are no longer present.
The Court's unanimous opinion, authored by Justice Elena Kagan, emphasized that "federal courts are courts of limited jurisdiction" and that the operative complaint dictates the scope of jurisdiction. The ruling clarified that when federal claims are removed, any related state-law claims must return to state court, irrespective of how the case originally entered the federal system.
Trip Coyne, one of the Ward and Smith attorneys representing the plaintiff, reflected on the significance of the decision:
"This ruling reinforces the principle that plaintiffs have the right to control their cases and ensures that state courts remain the appropriate forum for state-law claims when federal questions are not in play. It's a meaningful step toward maintaining fairness and clarity in our legal system."
The Supreme Court's decision not only resolves a circuit split but also sets a clear precedent for future jurisdictional disputes in both original and removed cases. The team's compelling arguments highlighted the importance of respecting statutory frameworks and maintaining judicial consistency, an approach that resonated strongly with the Court.
