Plain-English summary
Court affirms vacatur where federal case lacked diversity because a non‑diverse defendant was wrongly dismissed after it
The Court held that a federal judgment entered after removal must be vacated when the district court mistakenly dismissed a non‑diverse defendant whose presence destroyed complete diversity at the time of removal. The Fifth Circuit’s vacatur of the judgment for Hain Celestial Group was affirmed and the case remanded.
Why this matters
The decision makes clear that federal courts cannot keep judgments simply because a non‑diverse defendant is later dismissed for procedural reasons. Parties and courts must ensure that the diversity requirement is satisfied at the time of removal; otherwise judgments entered in federal court may be undone even after final judgment.
Who may feel it
- Civil plaintiffs and defendants in diversity cases
- Federal and state trial courts handling removed cases
- Lawyers who litigate jurisdictional and removal disputes
- Businesses facing cross‑state litigation
Key questions
- Does a district court’s later dismissal of a non‑diverse defendant cure a lack of complete diversity that existed at the time of removal?
- Must a federal court vacate a final judgment entered when the court lacked diversity jurisdiction at removal, even if the non‑diverse defendant was dismissed later for procedural reasons?