Royal Canin U. S. A. v. Wullschleger
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Royal Canin U. S. A. v. Wullschleger and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Royal Canin U. S. A. v. Wullschleger.
In Royal Canin U.S.A. v. Wullschleger, the Supreme Court addressed whether a federal court retains jurisdiction over state-law claims after a plaintiff amends a complaint to remove federal claims. The Court concluded that such amendments divest the federal court of supplemental jurisdiction, requiring remand to state court. This decision clarifies the impact of amended pleadings on jurisdiction in removed cases.
Holding
The single most important “bottom line” of what the Court decided in Royal Canin U. S. A. v. Wullschleger.
The Court held that when a plaintiff amends a complaint to remove federal claims, the federal court loses supplemental jurisdiction over state claims, necessitating remand to state court.
Constitutional Concepts
These are the Constitution-related themes that appear in Royal Canin U. S. A. v. Wullschleger. Click a concept to see other cases that involve the same idea.
-
Why Judicial Review is relevant to Royal Canin U. S. A. v. Wullschleger
The case involves the federal court's authority to review jurisdiction based on the amended complaint.
Syllabus excerpt (verbatim)So under § 1367(a), when the plaintiff in an original case amends her complaint to withdraw the federal claims, leaving only state claims behind, she divests the federal court of supplemental jurisdiction.
-
Why Procedural Due Process is relevant to Royal Canin U. S. A. v. Wullschleger
The case addresses procedural aspects of jurisdiction and the proper forum for litigation.
Syllabus excerpt (verbatim)When a plaintiff amends her complaint to delete the federal-law claims that enabled removal to federal court, leaving only state-law claims behind, the federal court loses supplemental jurisdiction over the state claims, and the case must be remanded to state court.
-
Why State–Federal Power is relevant to Royal Canin U. S. A. v. Wullschleger
The decision involves the allocation of authority between state and federal courts.
Syllabus excerpt (verbatim)In the Eighth Circuit's view, Wullschleger's amendment had eliminated any basis for federal-question jurisdiction. And without a federal question, the court concluded, there was no possibility of supplemental jurisdiction over Wullschleger's state-law claims.
Key Quotes
Short excerpts from the syllabus in Royal Canin U. S. A. v. Wullschleger that support the summary and concepts above.
When a plaintiff amends her complaint to delete the federal-law claims that enabled removal to federal court, the federal court loses supplemental jurisdiction over the state claims.
The statute thus confers supplemental jurisdiction over state-law claims sharing a sufficient factual relationship with the federal claims in a case.
Rockwell's rule has a host of variations in both original and removed federal cases.
