NOTICE: This opinion is subject to
formal revision before publication in the United States Reports.
Readers are requested to notify the Reporter of Decisions, Supreme
Court of the United States, Washington, D. C. 20543,
[email protected], of any typographical or other formal
errors.
SUPREME COURT OF THE UNITED STATES
_________________
No. 23–677
_________________
ROYAL CANIN U. S. A., INC.,
et al., PETITIONERS
v. ANASTASIA WULLSCHLEGER,
et al.
on writ of certiorari to the united states
court of appeals for the eighth circuit
[January 15, 2025]
Justice Kagan delivered the opinion of the
Court.
If a complaint filed in state court asserts
federal-law claims, the defendant may remove the case to federal
court. See 28 U. S. C. §1441(a). And if the complaint
also asserts state-law claims arising out of the same facts, the
federal court may adjudicate those claims too, in the exercise of
what is called supplemental jurisdiction. See §1367.
This case presents a further question: What
happens if, after removal, the plaintiff amends her complaint to
delete all the federal-law claims, leaving nothing but state-law
claims behind? May the federal court still adjudicate the now
purely state-law suit? We hold that it may not. When an amendment
excises the federal-law claims that enabled removal, the federal
court loses its supplemental jurisdiction over the related
state-law claims. The case must therefore return to state
court.
I
A
“Federal courts,” we have often explained,
“are courts of limited jurisdiction.”
E.g.,
Kokkonen
v.
Guardian Life Ins. Co. of America,
511 U.S.
375, 377 (1994). Limited first by the Constitution, to only the
kinds of “Cases” and “Controversies” listed in Article III. And for
all lower federal courts, limited as well by statute. Congress
determines, through its grants of jurisdiction, which suits those
courts can resolve. So, for example, Congress has always given
federal courts power to decide “diversity” cases, between “citizens
of different States” whose dispute involves more than a stated sum
(the so-called amount-in-controversy). §1332(a). And of special
importance here, Congress has long conferred jurisdiction on
federal courts to resolve cases “arising under” federal law.
§1331.
“Arising under” jurisdiction—more often known as
federal-question jurisdiction—enables federal courts to decide
cases founded on federal law. A suit most typically falls within
that statutory grant “when federal law creates the cause of action
asserted.”
Gunn v.
Minton,
568
U.S. 251, 257 (2013). On rare occasions, the grant also covers
a suit containing state-law claims alone, because one or more of
them “necessarily raise[s]” a “substantial” and “actually disputed”
federal question.
Id., at 258. Either way, the determination
of jurisdiction is based only on the allegations in the
plaintiff ’s “well-pleaded complaint”—not on any issue the
defendant may raise.
Franchise Tax Bd. of Cal. v.
Construction Laborers Vacation Trust for Southern Cal.,
463 U.S.
1, 9–10 (1983). That longstanding rule makes the complaint—the
plaintiff ’s own claims and allegations—the key to “arising
under” jurisdiction. If the complaint presents no federal question,
a federal court may not hear the suit.
But if a complaint includes the requisite
federal question, a federal court often has power to decide
state-law questions too. Suppose a complaint with two claims—one
based on federal, the other on state, law. This Court held in
Mine Workers v.
Gibbs,
383 U.S.
715, 725 (1966), that a federal court may exercise supplemental
jurisdiction over the state claim so long as it “derive[s] from”
the same “nucleus of operative fact” as the federal one. The
Gibbs Court reasoned that when the two claims are so closely
related, they make up “but one constitutional ‘case’ ”; and
the Court presumed that Congress wanted in that situation to confer
jurisdiction up to the Constitution’s limit.
Ibid. (quoting
U. S. Const., Art. III, §2, cl. 1); see
Exxon
Mobil Corp. v.
Allapattah Services, Inc.,
545 U.S.
546, 553 (2005). Congress later confirmed that view, generally
codifying
Gibbs’s supplemental-jurisdiction rule in 28
U. S. C. §1367 (whose text we will soon consider, see
infra, at 7–8). Under that statute, as under
Gibbs,
jurisdiction over a federal-law claim brings with it supplemental
jurisdiction over a state-law claim arising from the same facts.
That derivative jurisdiction, though, is to some extent
discretionary; §1367 spells out circumstances, again derived from
Gibbs, in which a federal court may decline to hear a state
claim falling within the statute’s bounds. See §1367(c);
Gibbs, 383 U. S., at 726–727.
And yet one more preparatory point: If a statute
confers federal jurisdiction over a suit, not only the plaintiff
but also the defendant can get it into federal court. Take the
“arising under” statute: It grants federal district courts
“original jurisdiction” over cases presenting a federal question.
§1331; see §1332 (similarly providing “original jurisdiction” over
diversity suits). The plaintiff may avail herself of that
jurisdiction (and of the opportunity §1367 affords to add
supplemental state claims); but she also may file her suit in state
court. If she takes the latter route, another statute then gives
the defendant an option. Because the case falls within the federal
courts’ “original jurisdiction,” the defendant may “remove[ ]” it
from state to federal court. §1441(a). And there the case
(including supplemental state claims) usually remains. Except that
“[i]f at any time before final judgment it appears that the
district court lacks subject matter jurisdiction,” the case must be
“remanded” to state court. §1447(c). That is because, to return to
where we started, federal courts are courts of limited
jurisdiction: When they do not have (or no longer have)
authorization to resolve a suit, they must hand it over.
B
Before raising issues demanding a
jurisdictional primer, this case was all about the marketing of dog
food. Petitioner Royal Canin U. S. A., Inc., manufactures
a brand of dog food available only with a veterinarian’s
prescription—and thus sold at a premium price. Respondent Anastasia
Wullschleger purchased the food, thinking it contained medication
not found in off-the-shelf products. She later learned it did not.
Her suit, initially filed in a Missouri state court, contends that
Royal Canin’s dog food is ordinary dog food: The company sells the
product with a prescription not because its ingredients make that
necessary, but solely to fool consumers into paying a jacked-up
price. Her original complaint asserted claims under the Missouri
Merchandising Practices Act and state antitrust law. It also
alleged violations of the Federal Food, Drug, and Cosmetic Act
(FDCA), 21 U. S. C. §301
et seq.
And so began the procedural back-and-forth that
eventually landed Wullschleger’s case in this Court. Royal Canin
went first: It removed the case to federal court based on the
asserted violations of the FDCA.[
1] That removal properly brought to the District Court not
only Wullschleger’s FDCA claims, but also her factually intertwined
state-law claims. The parties were thus set to litigate the entire
suit in federal court. But that is not where Wullschleger wanted
the case to be resolved. So she countered Royal Canin’s move: She
amended her complaint to delete its every mention of the FDCA,
leaving her state claims to stand on their own. And with that
amended, all-state-law complaint in hand, she petitioned the
District Court to remand the case to state court.
Although the District Court denied
Wullschleger’s request, the Court of Appeals for the Eighth Circuit
reversed that decision and ordered a remand. See 75 F. 4th 918, 924
(2023).[
2] In the Eighth
Circuit’s view, Wullschleger’s amendment had eliminated any basis
for federal jurisdiction. An amended complaint, the court reasoned,
“[supersedes] an original complaint and renders the original
complaint without legal effect.”
Id., at 922 (alteration in
original). And nothing in the amended complaint supported
federal-question jurisdiction: It was, after all, now based
entirely on state law. Nor could the District Court now exercise
supplemental jurisdiction over Wullschleger’s state-law claims.
“[T]he possibility of supplemental jurisdiction,” the court
reasoned, “vanished right alongside the once- present federal
questions.”
Id., at 924. And that analysis held good even
though it was Royal Canin, rather than Wullschleger, that had
brought the suit to the District Court: “It makes no difference,”
the Eighth Circuit stated, that the case “end[ed] up in federal
court through removal.”
Id., at 922.
Other Courts of Appeals have reached the
opposite conclusion, holding that a post-removal amendment cannot
divest a federal court of jurisdiction.[
3] On that view, “[t]he existence of subject matter
jurisdiction is determined by examining the complaint as it existed
at the time of removal.”
Harper v.
AutoAlliance Int’l,
Inc.,
392
F.3d 195, 210 (CA6 2004). So the District Court here would have
retained supplemental jurisdiction over Wullschleger’s state-law
claims even after she amended her complaint to delete all her
federal-law ones.
We granted certiorari to resolve the Circuit
split, 601 U. S. ___ (2024), and we now affirm the decision
below.
II
When a plaintiff amends her complaint
following her suit’s removal, a federal court’s jurisdiction
depends on what the new complaint says. If (as here) the plaintiff
eliminates the federal-law claims that enabled removal, leaving
only state-law claims behind, the court’s power to decide the
dispute dissolves. With the loss of federal-question jurisdiction,
the court loses as well its supplemental jurisdiction over the
state claims. That conclusion fits the text of §1367, governing
supplemental jurisdiction. And it accords with a bevy of rules
hinging federal jurisdiction on the allegations made in an amended
complaint, because that complaint has become the operative one.
Royal Canin argues that our precedent makes an exception for when
an amendment follows a lawsuit’s removal, but that is to read two
bits of gratuitous language for a good deal more than they are
worth.
A
Begin with §1367, entitled “Supplemental
jurisdiction.” Subsection (a) states the basic rule:
“Except as provided in subsections (b) and
(c) or as expressly provided otherwise by Federal statute, in any
civil action of which the district courts have original
jurisdiction, the district courts shall have supplemental
jurisdiction over all other claims that are so related to claims in
the action within such original jurisdiction that they form part of
the same case or controversy under Article III of the United States
Constitution.”
The subsection thus takes as its starting point
claims within a federal district court’s original
jurisdiction—because, say, they turn on federal law. See §1331. It
then confers authority on the court to decide certain “other”
claims in the same suit, involving only state law. That added
authority—the court’s supplemental jurisdiction—extends to claims
“so related to” the claims supporting original jurisdiction as to
form “part of the same [constitutional] case.” And that needed
relationship,
Gibbs explains, is one of fact: The federal
court has supplemental jurisdiction over state-law claims sharing a
“common nucleus of operative fact” with the federal-law ones. 383
U. S., at 725; see
supra, at 2–3.
Skip down a bit and subsection (c) explains that
the supplemental jurisdiction just conferred is in some measure
discretionary. That subsection provides that a district court “may
decline to exercise supplemental jurisdiction” in three specific
situations: (1) if the supplemental claim “raises a novel or
complex issue of State law”; (2) if the supplemental claim
“substantially predominates” over the claims within the court’s
original jurisdiction; and (3) if the district court “has dismissed
all claims over which it has original jurisdiction.”[
4] In all those contexts, federal law is not
where the real action is. So although supplemental jurisdiction
persists, the district court need not exercise it: Instead, the
court may (and indeed, ordinarily should) kick the case to state
court. See
Gibbs, 383 U. S., at 726–727.
In addressing the text of §1367, Royal Canin
argues primarily from the first subsection’s grant of jurisdiction.
The language there is “broad,” the company says: Section 1367(a)
grants “supplemental jurisdiction over ‘
all other claims’
within the case or controversy,
unless Congress ‘expressly
provided otherwise.’ ” Reply Brief 2 (emphasis in original).
And Congress did not expressly provide that an amendment deleting
federal claims eliminates supplemental jurisdiction. See
id., at 4–5. The upshot, Royal Canin says, is the rule it
espouses: The amendment of a complaint following removal of a suit
to federal court cannot divest that court of supplemental
jurisdiction.
But that position founders on an undisputed
point: Nothing in §1367’s text—including in the text Royal Canin
highlights—distinguishes between cases removed to federal court and
cases originally filed there. See Tr. of Oral Arg. 7–8. Whatever
that text says about removed cases, it also says about original
ones, and vice versa. That means if (as Royal Canin urges)
§1367(a)’s language prevents an amendment from ousting supplemental
jurisdiction in removed cases, then so too it does in original
ones. But here is the rub: In original cases, this Court has
already reached the opposite conclusion. The pertinent rule comes
from
Rockwell Int’l Corp. v.
United States,
549 U.S.
457, 473–474 (2007): “[W]hen a plaintiff files a complaint in
federal court and then voluntarily amends the complaint, courts
look to the amended complaint to determine jurisdiction.” So 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 adjudicatory power. See
ibid. Royal
Canin concedes that result, as it must. See Tr. of Oral Arg. 6–7.
The position it adopts—applying only in removed cases—is indeed
designed not to collide with
Rockwell’s ruling. But once
§1367(a) is taken as consistent with
Rockwell, it cannot say
what the company posits. Under that provision—as under
Rockwell—an amendment excising all federal claims divests a
court of supplemental jurisdiction over the remaining state claims
in an original case. And if in an original case, then also in a
removed case—because, again, §1367(a) draws no distinction between
the two.
The exclusion from §1367(a) of such
post-amendment state-law claims is reflected in the text of
§1367(c). Recall that §1367(c) describes three contexts in which
state-law claims, though covered by §1367(a)’s jurisdictional
grant, are often better given to state courts. See
supra, at
7–8. If §1367(a)’s grant included the leftover state claims in an
amended complaint, they too would have appeared on §1367(c)’s list:
Even more than the claims addressed there, they are ill-suited to
federal adjudication. The leftover state claims, after all, are now
the entirety of the plaintiff ’s suit. Federal claims are not
just subordinate, as in §§1367(c)(1) and (2), but gone. And gone
for good as well. When federal claims are dismissed by the district
court, as in §1367(c)(3), an appellate court may yet revive them;
but that cannot happen when the plaintiff has excised them through
a proper amendment. So, again, it follows: If §1367(a) conferred
supplemental jurisdiction over the claims here, §1367(c) would make
that jurisdiction discretionary. That §1367(c) does not do so—that
even while it addresses, for example, dismissals of federal claims,
it makes no mention of amendments deleting them—shows that §1367(a)
does not extend so far. Or otherwise said, there is no discretion
to decline supplemental jurisdiction here because there is no
supplemental jurisdiction at all. Once the plaintiff has ditched
all claims involving federal questions, the leftover state claims
are supplemental to nothing—and §1367(a) does not authorize a
federal court to resolve them.
That result accords with Congress’s usual view
of how amended pleadings can affect jurisdiction. On that view,
apparent in varied federal statutes, an amendment can wipe the
jurisdictional slate clean, giving rise to a new analysis with a
different conclusion. Consider 28 U. S. C. §1653: It
states broadly that, in both trial and appellate courts,
“[d]efective allegations of jurisdiction may be amended” to ensure
that a case can go forward. So a case falling outside the federal
court’s jurisdiction can come within it by virtue of an amendment.
Or take the statute laying out procedures for removal. It provides
that even “if the case stated by the initial pleading is not
removable,” an amendment may make it so: The defendant can remove
the case after receiving “an amended pleading” establishing that
the case is newly subject to federal jurisdiction. §1446(b)(3); see
§1332(d)(7) (similarly providing that an “amended complaint” in a
proposed class action may create “[f]ederal jurisdiction”). In such
statutes, Congress conceives of amendments as having the potential
to alter jurisdiction. And just the same here. Section 1367
contemplates that when an amended complaint is filed, the
jurisdictional basis for the suit is reviewed anew. If nothing in
the amended complaint now falls “within [the federal court’s]
original jurisdiction,” then neither does anything fall within the
court’s “supplemental jurisdiction.” §1367(a). In the superseding
pleading, the state-law claims are just state-law claims, outside
§1367(a)’s purview.
B
That reading of §1367 also parallels a slew of
other, mainly judge-made procedural rules linking jurisdiction to
the amended, rather than initial, complaint. In multiple
contexts—involving both cases brought in federal court and cases
removed there—courts conceive of amendments to pleadings as
potentially jurisdiction-changing events. The amended complaint
becomes the operative one; and in taking the place of what has come
before, it can either create or destroy jurisdiction. Section 1367,
as laid out above, fits hand in glove with—indeed, embodies—that
familiar approach. A post-removal amendment can divest a federal
court of its supplemental jurisdiction because—as the usual
procedural principle holds—jurisdiction follows from (and only
from) the operative pleading.
Begin from the beginning: The plaintiff is “the
master of the complaint,” and therefore controls much about her
suit.
Caterpillar Inc. v.
Williams,
482 U.S.
386, 398–399 (1987). She gets to determine which substantive
claims to bring against which defendants. And in so doing, she can
establish—or not—the basis for a federal court’s subject-matter
jurisdiction. She may, for example, name only defendants who come
from a different State, or instead add one from her own State and
thereby destroy diversity of citizenship. See §1332(a). Or in cases
like this one, she may decide to plead federal-law claims, or
instead to allege state-law claims alone and thus ensure a state
forum. See §1331;
supra, at 2 (describing the well-pleaded
complaint rule).
And the plaintiff ’s control over those
matters extends beyond the time her first complaint is filed. If a
plaintiff amends her complaint, the new pleading “supersedes” the
old one: The “original pleading no longer performs any function in
the case.” 6 C. Wright, A. Miller, & M. Kane, Federal Practice
and Procedure §1476, pp. 636–637 (3d ed. 2010). Or as we put the
matter over a century ago: “When a petition is amended,” the “cause
proceeds on the amended petition.”
Washer v.
Bullitt
County,
110 U.S.
558, 562 (1884). So changes in parties, or changes in claims,
effectively remake the suit. And that includes its jurisdictional
basis: The reconfiguration accomplished by an amendment may bring
the suit either newly within or newly outside a federal court’s
jurisdiction.
That idea is the one
Rockwell invoked, as
earlier noted. See
supra, at 8–9. Recall the situation there
considered: “[A] plaintiff files a complaint in federal court and
later voluntarily amends the complaint” to “withdraw[ ]” the
allegations supporting federal jurisdiction.
Rockwell, 549
U. S., at 473–474. Should the suit proceed? “[C]ourts,”
Rockwell replied, “look to the amended complaint to
determine jurisdiction.”
Id., at 474. That complaint is now
the operative one; the old complaint has become irrelevant. So
unless the withdrawn allegations were “replaced by others” giving
the court adjudicatory power, the plaintiff ’s amendment “will
defeat jurisdiction.”
Id., at 473. Or more specifically: If
a plaintiff files a suit in federal court based on federal claims
and later scraps those claims, the federal court cannot go forward
with a now all-state-claim suit. See
id., at
473–474.[
5]
That rule for original federal cases has a host
of variations, each tying jurisdiction to an amended pleading. If,
as
Rockwell spelled out, eliminating federal claims in such
a suit can destroy federal jurisdiction, the opposite is also true:
Adding federal claims can create federal jurisdiction where it once
was wanting. See,
e.g.,
ConnectU LLC v.
Zuckerberg, 522 F.3d 82, 91 (CA1 2008) (holding that an
amended complaint, which “replaced the original complaint lock,
stock, and barrel,” conferred jurisdiction). And so too, an
amendment can either destroy or create jurisdiction in an original
diversity case. The addition of a non-diverse party in such a case
typically destroys diversity jurisdiction, requiring the case’s
dismissal. See
Owen Equipment & Erection Co. v.
Kroger,
437 U.S.
365, 374–377 (1978) (stating that an amendment asserting claims
against a non- diverse party “destroy[s]” complete diversity “just
as surely as” joining that party in the first instance); see also,
e.g.,
American Fiber & Finishing, Inc. v.
Tyco
Healthcare Group, LP,
362 F.3d 136, 139 (CA1 2004).[
6] Conversely, the elimination of a non-diverse defendant
by way of amendment ensures that a case can proceed in federal
court, though it could not have done so before. See
Newman-Green, Inc. v.
Alfonzo-Larrain,
490 U.S.
826, 832–833 (1989). In short, the rule in original cases that
jurisdiction follows the amended (
i.e., now operative)
pleading applies across the board.
And still more: Similar rules have long applied
in the removal context. Not across the board, of course, else this
case would not have arisen: The very issue here is whether, in a
removed case (as in an original one), an amended complaint dropping
federal claims destroys jurisdiction. But in two of the other
situations discussed above, the rule in removed cases is the same
as the rule in original ones.[
7] First, in removed cases too, amending a complaint to
add a federal claim creates federal jurisdiction when it did not
previously exist. So even if removing a case was improper because
the initial complaint did not contain a federal claim, the
plaintiff ’s later assertion of such a claim establishes
jurisdiction going forward. See
Pegram v.
Herdrich,
530 U.S.
211, 215–216, and n. 2 (2000);
Bernstein v.
Lind-Waldock & Co., 738 F.2d 179, 185–186 (CA7 1984)
(Posner, J.). The federal court can thus resolve both the newly
added federal-law claim and the now supplemental state-law ones.
See
id., at 186–187. And second, in removed cases too,
amending a complaint to join a non-diverse party destroys diversity
jurisdiction. So if such a joinder occurs after removal, the
federal court must remand the case to the state court it began in.
See §1447(e);
Powerex Corp. v.
Reliant Energy Services,
Inc.,
551 U.S.
224, 231–232 (2007). Once again, federal jurisdiction—or its
absence—follows from the amended complaint.[
8]
The uniformity of that principle, as between
original and removed cases, is not surprising. The appropriateness
of federal jurisdiction—or the lack thereof—does not depend on
whether the plaintiff first filed suit in federal or state court.
Rather, it depends, in either event, on the substance of the
suit—the legal basis of the claims (federal or state?) and the
citizenship of the parties (diverse or not?). (That focus on
substance is indeed why original jurisdiction and removal
jurisdiction generally mirror each other in scope. See §1441(a).)
So in a removed no less than in an original case, the rule that
jurisdiction follows the operative pleading serves a critical
function. It too ensures that the case, as it will actually be
litigated, merits a federal forum.
And with all that recognized, the answer to the
disputed question here becomes yet more certain: On top of §1367, a
panoply of procedural rules shows that a post-removal amendment
excising all federal claims destroys federal jurisdiction. Under
those rules, the presence of jurisdiction, in removed as in
original cases, hinges on the amended, now operative pleading. By
adding or subtracting claims or parties, and thus reframing the
suit, that pleading can alter a federal court’s authority. And so
it is here. When a plaintiff, after removal, cuts out all her
federal-law claims, federal-question jurisdiction dissolves. And
with any federal anchor gone, supplemental jurisdiction over the
residual state claims disappears as well. The operative pleading no
longer supports federal jurisdiction, and the federal court must
remand the case to the state court where it started.
C
Royal Canin contends that this Court has twice
before reached the opposite conclusion—first, in
Carnegie-Mellon
Univ. v.
Cohill,
484 U.S.
343 (1988), and next in
Rockwell, in a footnote to the
analysis we have related above. See
supra, at 8–9, 12. But
in each case, the relied-on passage is extraneous to the Court’s
holding and reasoning, and so cannot bear the weight of Royal
Canin’s argument.
Begin with
Cohill, which shares the
procedural posture of this case but asked and answered a different
question. There, as here, the plaintiff filed a suit in state
court, asserting both federal and state claims; the defendant
removed the suit to federal court; and the plaintiff then dropped
her federal claim and sought a remand. The District Court granted
that request over the defendant’s objection. But in opposing that
ruling, the defendant did not argue (à la Royal Canin) that the
court should have held on to the case. Rather, the defendant urged
that the court should have dismissed the case outright instead of
remanding it. (The difference mattered because the statute of
limitations had by then expired, and a dismissal would have ended
the suit.) The disputed issue was thus not about keeping the case
in federal court, but about two different ways of expelling it. Or
as
Cohill put it: The question “present[ed] is whether the
District Court could relinquish jurisdiction over the case only by
dismissing it without prejudice or whether the District Court could
relinquish jurisdiction over the case by remanding it to state
court as well.” 484 U. S., at 351. We held that the federal
court could remand as well as dismiss, even though no statute then
authorized the former action.
Id., at 357; see §1447(c) (now
filling that vacuum). Our reasoning, in that pre-§1367 era, focused
on the values served by supplemental jurisdiction, as set out in
Gibbs. “[E]conomy, convenience, fairness, and comity,” we
stated, “support[ ] giving a district court discretion to
remand when the exercise of [supplemental] jurisdiction is
inappropriate.”
Cohill, 484 U. S., at 351. So when a
plaintiff cuts her federal claims, the court should have a choice
about how best to get rid of the case.
In one spot, though, the
Cohill Court
intimated a view on whether the District Court also had discretion
to retain the suit. The sentence, pressed by Royal Canin, comes
just before the Court’s statement of the question presented, quoted
above. See Brief for Petitioners 10–11, 19. It reads: “When the
single federal-law claim in the action was eliminated at an early
stage of the litigation, the District Court had a powerful reason
to choose not to continue to exercise jurisdiction.”
Cohill,
484 U. S., at 351. In using the word “choose,”
Cohill
suggested that the court, though having strong cause to dismiss or
remand, likewise had authority to decide the case.
But that slender (and somewhat backhanded)
dictum cannot make us stop in our tracks. Nowhere did
Cohill
analyze why a federal court could retain jurisdiction once an
amendment excised all federal-law claims.
Cohill simply
supposed the court could and asserted as much, without pausing to
consider the matter. And that lack of scrutiny reflected the
issue’s lack of importance—not in today’s case of course, but in
that earlier one. As just explained, the District Court in
Cohill never thought to exercise jurisdiction after the
amendment; the issue in dispute was only how to get rid of the
action. So
Cohill’s view about keeping jurisdiction was
gratuitous, and no sooner noted than dropped. It supported neither
the decision’s result nor its values-based reasoning. And anyway,
our own analysis is based mainly on legal authorities post-dating
Cohill—most notably, §1367 and our
Rockwell decision.
See
supra, at 6–10, 12. Those later materials supersede
whatever
Cohill presumed about exercising federal
jurisdiction in a case like this one. So by virtue of both what it
decided and when it arose,
Cohill does not matter to the
question before us.
That leaves the
Rockwell footnote Royal
Canin cites. As earlier explained, the body of
Rockwell
examines what happens in an original case when a plaintiff amends a
complaint to expunge federal claims. See
supra, at 8–9, 12.
The federal court,
Rockwell held, loses jurisdiction. See
549 U. S., at 473–474. But in a two-sentence footnote, the
Rockwell Court said that the opposite rule applies in
removed cases. “[W]hen a defendant removes a case to federal court
based on the presence of a federal claim,” the footnote stated, “an
amendment eliminating the original basis for federal jurisdiction
generally does not defeat jurisdiction.”
Id., at 474, n. 6.
That is because “removal cases raise forum-manipulation concerns
that simply do not exist when it is the
plaintiff who
chooses a federal forum and then pleads away jurisdiction through
amendment.”
Ibid. (emphasis in original). The footnote thus
sets out exactly the rule Royal Canin wants—and, in so doing, gives
the company its best argument.
But still, the footnote is dictum, and does not
control the outcome here.
Rockwell was an original federal
case, not a removed one. So the footnote’s assertion of a special
rule for removed cases was outside the issue being decided—or more
colloquially put, beside the point. The statement had no bearing on
the Court’s conclusion about jurisdiction in original cases. Nor
did it relate to the rationale supporting that result. And to top
it off, the footnote was itself barely reasoned.[
9] This Court has often stated that “drive-by
jurisdictional rulings”—asserting or denying jurisdiction “without
elaboration,” or analysis of whether anything “turn[ed] on” the
ruling—should be accorded “no precedential effect.”
Wilkins
v.
United States, 598 U.S. 152, 160 (2023) (quoting
Arbaugh v.
Y & H Corp.,
546
U.S. 500, 511, 512 (2006); alteration in original;
Henderson v.
Shinseki,
562 U.S.
428, 437 (2011)). The admonition goes double for throwaway
footnotes about jurisdictional issues neither raised in nor
conceivably relevant to a case. We therefore need not follow the
Rockwell footnote just because it exists; our adherence
instead depends on whether it withstands analysis.[
10]
And it does not, for all the reasons already
given. A recap here fittingly begins with
Rockwell’s own
core insight, which points the opposite way. Federal courts,
Rockwell stated, “look to the amended complaint to determine
jurisdiction.” 549 U. S., at 474. That rule, as earlier
described, explains a host of jurisdictional outcomes. See
supra, at 11–14. It operates in federal-question cases and
diversity cases, both to destroy and to create jurisdiction. And it
cannot give way, in a case like this one, just because the case was
removed from state to federal court. When, as here, a complaint
asserts both federal and state claims, and an amendment strips out
the federal ones, a district court’s jurisdiction depends on §1367.
And §1367, as earlier shown, makes no distinction between cases
beginning in federal court and cases removed there. See
supra, at 8–9. If in the former the amendment “defeat[s]
jurisdiction,” as
Rockwell rightly held, 549 U. S., at
473, then so too in the latter. Regardless of removal, the
plaintiff ’s excision of her federal-law claims deprives the
district court of its authority to decide the state-law claims
remaining.
III
For those reasons, the District Court here
should have remanded Wullschleger’s suit to state court. The
earliest version of that suit contained federal-law claims and
therefore was properly removed to federal court. The additional
state-law claims were sufficiently related to the federal ones to
come within that court’s supplemental jurisdiction. But when
Wullschleger amended her complaint, the jurisdictional analysis
also changed. Her deletion of all federal claims deprived the
District Court of federal-question jurisdiction. And once that was
gone, the court’s supplemental jurisdiction over the state claims
dissolved too. Wullschleger had reconfigured her suit to make it
only about state law. And so the suit became one for a state
court.
We accordingly affirm the judgment of the Court
of Appeals for the Eighth Circuit.
It is so ordered.