Hain Celestial Group v. Palmquist
Decision
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Opinion of the Court
Overview
Overview
This is a Supreme Court case about subject matter jurisdiction and diversity jurisdiction. A Texas mother sued Hain Celestial Group over allegedly contaminated baby food, but included Whole Foods (a Texas company) as a co-defendant, which destroyed diversity jurisdiction and allowed the case to remain in Texas state court. The case is now before the Supreme Court to decide whether the plaintiff gets a full do-over in state court after the Fifth Circuit ruled that the district judge improperly removed Whole Foods and sent the case to federal court.
The Issue
Issue
Whether a plaintiff is entitled to a complete do-over in state court when a federal district court improperly removes a case despite the destruction of diversity jurisdiction caused by the inclusion of a non-diverse defendant.
The Rules
Rule
Complete diversity of citizenship is required for federal jurisdiction in diversity cases; a case must remain in or return to state court if diversity jurisdiction is absent or destroyed. Improper removal violates the federal court's subject matter jurisdiction.
The Application
Analysis
The plaintiff, a Texas resident, named Whole Foods (also a Texas company) as a co-defendant alongside Hain Celestial Group, destroying the complete diversity required for federal jurisdiction. The district court nevertheless removed the case to federal court, and the Fifth Circuit identified this removal as procedurally improper.
The Conclusion
The Supreme Court affirmed the Fifth Circuit unanimously (Sotomayor for the Court; Thomas, J., concurring), decided February 24, 2026. Because the district court's erroneous dismissal of Whole Foods, a non-diverse defendant, did not cure the jurisdictional defect that existed when Hain removed the case, the federal judgment in Hain's favor had to be vacated and the case returned to Texas state court.
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