Royal Canin U.S.A., Inc. v. Wullschleger (23-677)
argument 23-677Royal Canin U.S.A., Inc. v. Wullschleger
Supreme Court of the United States
1h 5m
8 speakers
8 chapters
transcribed 1 month ago
official recording ↗
Transcript
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Transcript generated automatically by AI and may contain errors.
Why does the Court consider the Eighth Circuit’s decision an extreme outlier?
We'll hear argument next in case twenty three six seven seven, Royal Canaan versus Wolfslager. Ms. Wellington.
Mr Chief Justice and may it please the court, the eighth circuit's decision below is an extreme outlier. It conflicts with the text and structure of Section thirteen sixty seven and with more than a century of precedent. Chief Justice Marshall held in Molin against Torrance in 1824 that in a diversity case, a federal court's jurisdiction, once vested, cannot be divested by subsequent events. The court extended that reasoning to removal actions in Kirby against American Soda in 1904. In 1938, this court held in St. Paul Mercury that if the plaintiff, after removal, amends his pleadings, This does not deprive the district court of jurisdiction because the defendant's statutory right to removal should not be subject to the plaintiff's caprice.
The second Justice Marshall confirmed that conclusion in Carnegie Mellon against Cohill in nineteen eighty eight, and Justice Scalia concurred in Rockwell in two thousand and seven. Respondents asked this court to upset that settled interpretation, claiming that it conflicts with the text of Section thirteen sixty seven. But Congress codified this court's long standing precedent in the text of Section thirteen sixty seven itself. Making clear that if the Federal Court has original jurisdiction, it shall continue to have supplemental jurisdiction unless Congress expressly provided otherwise. Respondents cannot cite a single decision of this court, a single decision of a Court of Appeals outside of the Eighth Circuit, or a single treatise that supports their position.
Respondents realize how weak their case is and instead asked the court to decide something else whether Graebel should be overruled and if not whether Graebel's requirements were met. This court did not grant Sir Shararai on either question. Grable has settled law and the eighth circuit correctly applied it here. The Court should affirm its longstanding precedent and reverse the decision below. I welcome the Court's questions.
Um you mentioned Section thirteen sixty seven. Uh could you spend a few minutes uh on your argument uh as to how it disposes of uh supports your argument?
Certainly, Your Honor. So the text of Section thirteen sixty-seven states that there is supplemental jurisdiction unless Congress has expressly provided otherwise. And the text of Section 1367 does not say that when a plaintiff amends the complaint to delete the federal question, there is no longer supplemental jurisdiction. And that's exactly the interpretive approach that this court adopted in ExxonMobil against Allapada, where the court was trying to figure out what does section thirteen sixty-seven say about Rule 23. and plaintiffs in class actions. And the court looked at Section 1367, said it doesn't say anything about Rule 23, and that means that there is supplemental jurisdiction. There are also some important structural inferences here.
So so Section 1367 C three makes clear that where the district court has dismissed all claims over which it has original jurisdiction, it can continue to exercise supplemental jurisdiction. And that really disposes of the argument that there has to be an ongoing federal question in the case in order for supplemental jurisdiction to be warranted. Congress didn't intend that here. So do you think, Ms. Wellington, that l let's say this wasn't a removal case, let's say this was an original case and it was brought in federal court. And then the plaintiff took out the federal claim, leaving only state claims. Is there supplemental jurisdiction there? So this Court has treated these two situations differently, and Justice Scalia explained why in Rockwell.
So there is a concern in Rockwell that when a plaintiff goes into federal court, pleads a federal question, and then immediately or subsequently drops it, that they are trying to plead their way into federal court. So forgetting what the reason for that is, you do agree with that rule that once uh I I file
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Chapters
8 chapters
1
Why does the Court consider the Eighth Circuit’s decision an extreme outlier?
0:00–6:13
2
How does Section 1367’s text support the argument for continued supplemental jurisdiction?
6:13–9:46
3
Does removing a case to federal court change the effect of an amendment that drops federal claims?
9:46–16:35
4
Is the plaintiff’s late amendment an example of forum‑manipulation?
16:35–25:03
5
What role does Rule 15’s amendment window play in determining jurisdiction after removal?
25:03–31:09
6
Why should district courts retain discretion over supplemental jurisdiction in complex, long‑running cases?
31:09–37:11
7
How does footnote six and prior precedent influence the Court’s analysis of this case?
37:11–42:45
8
What are the implications of overturning the Eighth Circuit’s decision for future removal and jurisdiction cases?
42:45–1:05:21