On this episode, Professors Laura Dooley and John Quinn discuss Royal Canin U.S.A., Inc. v. Wullschleger, a recent Supreme Court case involving federal subject matter jurisdiction.
Royal Canin is a straightforward case: In a unanimous decision, the Court held that when a plaintiff amends her complaint to eliminate all federal law claims and include only state law claims after the case is removed to federal court, the plaintiff’s case can
no longer be heard in federal court. There is no original subject matter jurisdiction because there are no federal law claims, and there is no supplemental jurisdiction over the remaining state law claims. Accordingly, the case must be remanded to state court.
As Professors Dooley and Quinn explain, Royal Canin is a helpful case for understanding all aspects of federal subject matter jurisdiction: original jurisdiction, removal, and supplemental jurisdiction. Along with moderator Rodger Citron, who also teaches Civil Procedure, they discuss how they plan to use the case with their students.