Plain-English summary
Court unanimously holds that deleting federal claims after removal requires remand of remaining state-law claims
The Supreme Court unanimously held that when a plaintiff amends a complaint after removal to delete the federal-law claims that gave the federal court jurisdiction, the federal court loses supplemental jurisdiction over the remaining state-law claims and must remand the case to state court. The decision affirms the Eighth Circuit.
Why this matters
The ruling clarifies how federal jurisdiction works after a plaintiff strips away the federal basis for removal. It prevents federal courts from keeping state-law disputes that no longer rest on a federal question, preserving the line between state and federal court authority and limiting tactical forum manipulation.
Who may feel it
- Plaintiffs and defendants in cases removed from state to federal court based on federal-law claims
- Federal and state trial courts handling removed cases
- Civil litigants and their attorneys who consider adding or dropping federal claims strategically
Key questions
- Does a post-removal amendment that eliminates the federal claim defeat federal-question subject-matter jurisdiction?
- Does elimination of the federal claim after removal preclude the district court from exercising supplemental jurisdiction over the remaining state-law claims under 28 U.S.C. § 1367?