The question
Whether a plaintiff who amends her complaint after removal to delete the federal-law claims that permitted removal thereby strips the federal court of supplemental jurisdiction over the remaining state-law claims.
Royal Canin U. S. A. v. Wullschleger
What the Court decided
The Court affirmed the Eighth Circuit and held that when a plaintiff amends her complaint to delete the federal-law claims that enabled removal, leaving only state-law claims, the federal court loses supplemental jurisdiction and the case must be remanded to state court. The reason is textual: 28 U.S.C. section 1367(a) grants supplemental jurisdiction only over claims related to federal claims within the court's original jurisdiction, and once the federal claims are withdrawn the amended complaint controls the jurisdictional inquiry. The rule is the same whether a case was removed to federal court or originally filed there, because the statute's text draws no distinction between the two.
How the justices split
UnanimousThe Court's opinion
Kagan, writing alone
The text of 28 U.S.C. section 1367(a) confers supplemental jurisdiction only over state-law claims that share a sufficient factual relationship with federal claims within the court's original jurisdiction. Under Rockwell Int'l Corp. v. United States, courts look to the amended complaint to determine jurisdiction, so when a plaintiff amends to withdraw the federal claims she divests the federal court of supplemental jurisdiction. The result is the same in a removed case because nothing in section 1367(a)'s text distinguishes removed cases from those originally filed in federal court, and section 1367(c)'s omission of leftover post-amendment state claims confirms that section 1367(a) does not reach them.
How we know · 5 sourced claims
The Court held that a post-removal amendment deleting the federal-law claims that enabled removal divests the federal court of supplemental jurisdiction over the remaining state-law claims, requiring remand to state court.
Source: syllabus, Held
The holding rests on the text of 28 U.S.C. section 1367(a), which grants supplemental jurisdiction only over claims related to federal claims within the court's original jurisdiction.
Source: syllabus, Held
The Court relied on Rockwell Int'l Corp. v. United States, 549 U.S. 457, for the rule that courts look to the amended complaint to determine jurisdiction after a voluntary amendment.
Source: syllabus, Held
The rule applies identically to removed cases and cases originally filed in federal court because section 1367(a)'s text draws no distinction between them.
Source: syllabus, Held
Justice Kagan delivered the opinion for a unanimous Court.
Source: syllabus, lineup