Hain Celestial Group v. Palmquist | 11/04/25 | Docket #: 24-724
24-724 HAIN CELESTIAL GROUP V. PALMQUIST
DECISION BELOW: 103 F.4th 294
CERT. GRANTED 4/28/2025
QUESTION PRESENTED:
Respondents, citizens of Texas, filed this products-liability suit in state court
against Petitioners Hain Celestial Group, Inc., then a citizen of Delaware and New York,
and Whole Foods, Inc., a citizen of Texas. Hain removed based on diversity jurisdiction,
arguing that Whole Foods should be dismissed as fraudulently joined. The district court
agreed, dismissing Whole Foods with prejudice. After two additional years of federal-
court litigation and a two-week jury trial, the district court granted judgment as a matter
of law to Hain. On appeal, without ruling on the merits, the Fifth Circuit held that the
district court erred in dismissing Whole Foods, vacated the final judgment, and ordered
the matter remanded to state court to start from scratch. Relying on Respondents' post-
removal amended complaint, the panel held, in conflict with several other courts of
appeals, that the district court lacked jurisdiction to enter judgment as to the completely
diverse parties before it.
The questions presented are:
1.
Whether a district court's final judgment as to completely diverse parties
must be vacated when an appellate court later determines that it erred by dismissing a
non-diverse party at the time of removal.
2.
Whether a plaintiff may defeat diversity jurisdiction after removal by
amending the complaint to add factual allegations that state a colorable claim against a
nondiverse party when the complaint at the time of removal did not state such a claim
LOWER COURT CASE NUMBER: 23-40197