The Supreme Court ruled Wednesday that federal courts lose supplemental jurisdiction over state law claims when plaintiffs strategically amend their complaints to eliminate federal claims that originally justified removal from state court. The unanimous decision in *Royal Canin U.S.A., Inc. v. Wullschleger* resolves a circuit split on whether federal courts can retain jurisdiction over purely state law claims after the federal basis for jurisdiction disappears.
The case began when consumer Anastasia Wullschleger sued Royal Canin U.S.A., Inc. in state court, alleging the pet food manufacturer engaged in deceptive marketing practices. Her original complaint included claims under both federal and state law, providing Royal Canin with grounds to remove the case to federal court under 28 U.S.C. § 1441(a).
Under federal removal statutes, Royal Canin's removal was proper because Wullschleger's federal claims established federal-question jurisdiction under 28 U.S.C. § 1331. This federal jurisdiction also allowed the district court to exercise supplemental jurisdiction over the factually related state law claims under 28 U.S.C. § 1367.
However, Wullschleger preferred to litigate in state court rather than federal court. To achieve this goal, she amended her complaint to delete all federal law claims, leaving only state law allegations. She then petitioned the district court to remand the case back to state court, arguing that without federal claims, the federal court lacked jurisdiction.
The U.S. District Court denied Wullschleger's remand motion, finding that it retained jurisdiction over the case despite the amended complaint. The district court's reasoning reflected one approach taken by federal courts nationwide when confronting this jurisdictional question.
The U.S. Court of Appeals for the Eighth Circuit reversed the district court's decision. The Eighth Circuit held that Wullschleger's amendment eliminated the basis for federal-question jurisdiction entirely. Without any federal question remaining in the case, the appeals court concluded that supplemental jurisdiction over the state law claims could not be maintained under § 1367.
This ruling created tension with decisions from other circuit courts that had addressed similar situations. Some circuits had permitted federal courts to retain supplemental jurisdiction even after plaintiffs amended out federal claims, while others aligned with the Eighth Circuit's approach. The circuit split prompted the Supreme Court to grant certiorari to provide uniform guidance on this jurisdictional issue.
The Supreme Court's opinion, decided January 15, 2025, after oral arguments on October 7, 2024, clarified that federal courts lose supplemental jurisdiction when the federal claims that originally supported removal are eliminated through amendment. The Court's holding establishes that supplemental jurisdiction under § 1367 cannot exist independently of an underlying federal question.
The decision affects litigation strategy for both plaintiffs and defendants in cases involving mixed federal and state claims. Plaintiffs who prefer state court forums now have clear guidance that amending complaints to remove federal claims will likely result in remand to state court. Conversely, defendants seeking to maintain federal jurisdiction must ensure that viable federal claims remain in the case.
The ruling also impacts how federal courts handle supplemental jurisdiction more broadly. Courts must now dismiss cases or remand them to state court when plaintiffs successfully eliminate all federal questions through amendment, regardless of how factually intertwined the remaining state claims may be with the original federal allegations.
Legal practitioners specializing in removal and remand procedures will need to adjust their strategies in light of this precedent. The decision provides certainty for planning litigation approaches and resolves the uncertainty that existed due to conflicting circuit court decisions.
For Royal Canin specifically, the company will likely see its case remanded to state court where Wullschleger originally filed suit. The pet food manufacturer will need to defend against the deceptive marketing allegations in state court proceedings rather than federal court.
The decision represents a victory for plaintiffs' rights to choose their preferred forum when federal claims are not central to their legal theories. It also reinforces the principle that supplemental jurisdiction serves as an adjunct to, rather than a substitute for, independent federal jurisdiction.
The *Royal Canin* decision will influence countless removal and remand motions across federal district courts. Lower courts now have clear Supreme Court guidance on when supplemental jurisdiction terminates, eliminating the need for case-by-case analysis of whether amended complaints still support federal jurisdiction. This clarity should streamline jurisdictional determinations and reduce litigation over forum selection in cases involving both federal and state law claims.