Hain Celestial Group, Inc., et al. v. Palmquist, individually and as next friend of E. P., a minor, et al. (24-724)
- Term
- OT 2025
- Argued
- 2025-11-04
- Decided
- 2026-02-24
- Vote
- 9-0 for Palmquist
- Opinion
- Justice Sotomayor
- Majority
- Roberts, Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
The case in brief
Facts
Sarah and Grant Palmquist fed their son, E. P., baby food made by Hain Celestial Group and bought from Whole Foods Market, and he later developed serious conditions that some doctors blamed on heavy-metal poisoning. After a 2021 congressional report found toxic heavy metals in some baby foods, including Hain's, the Palmquists sued both companies in Texas state court. Hain moved ("removed") the case to federal court, but federal courts can hear such state-law cases only when no plaintiff lives in the same State as any defendant, and Whole Foods and the Palmquists were all Texas citizens. The federal trial court agreed with Hain that Whole Foods was "improperly joined," dismissed it, and later ruled for Hain after trial because the Palmquists had not proven causation. The Fifth Circuit appeals court found that Whole Foods should not have been dismissed, threw out the judgment, and sent the case back to state court, and the Supreme Court agreed to review that ruling.
Question
When a federal trial court wrongly drops a same-State defendant to create the out-of-state mix needed for federal jurisdiction, must an appeals court throw out the resulting judgment?
Conclusion
The Palmquists won in a unanimous 9-0 decision written by Justice Sotomayor. The Court held that the trial court's mistaken, temporary dismissal of Whole Foods did not fix the jurisdiction problem that existed when the case was removed, so the judgment for Hain had to be thrown out. It reasoned that a court cannot create its own jurisdiction through its own mistakes, that saving time does not excuse a jurisdiction defect, and that a defendant cannot use a procedural rule to drop a properly sued co-defendant and override the plaintiffs' choice of state court. Justice Thomas wrote a concurring opinion questioning whether the "improper joinder" doctrine is valid at all.
Opinion of the Court
Authored by Justice Sotomayor (5,959 words total).
Volume 607 U. S. Part 2 Pages 421–437
THE SUPREME COURT February 24, 2026
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A NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors.
HAIN CELESTIAL GROUP, INC., et al. v. PALMQUIST, individually and as next friend of E. P., a minor, et al. certiorari to the united states court of appeals for the fth circuit No. 24–724. Argued November 4, 2025—Decided February 24, 2026 Respondents Sarah and Grant Palmquist fed their child E. P. baby food that was made by petitioner Hain Celestial Group, Inc., and that they purchased from petitioner Whole Foods Market, Inc. When E. P. was 2½ years old, he began exhibiting serious developmental disorders and was diagnosed with a range of physical and mental conditions that some doctors attributed to heavy-metal poisoning. In 2021, a subcommittee of the U. S. House of Representatives released a staff report fnding that certain baby foods, including Hain's, contained elevated levels of toxic heavy metals. Following the report's release, the Palmquists sued both Hain and Whole Foods in Texas state court, alleging state-law product liability and negligence claims against Hain, and state-law breach-ofwarranty and negligence claims against Whole Foods. Hain, a Delaware corporation with a principal place of business in New York, removed the case to federal court based on diversity of citizenship, but confronted a problem: Federal courts may exercise diversity jurisdiction only when no adverse party is from the same State, but Whole Foods and the Palmquists are all Texas citizens. As a result, the District Court lacked jurisdiction as the case stood upon removal. Hain sought to cure this problem by arguing in its notice of removal that Whole Foods had been improperly joined in the lawsuit and should be dismissed, which would have established complete diversity between Hain and the Palmquists. The District Court agreed with Hain, dismissed Whole Foods, and denied the Palmquists' motion to remand. The case then went to trial against Hain alone in federal court. The District Court granted Hain's motion for judgment as a matter of law on all claims, explaining that the Palmquists had failed to present suffcient evidence to prove causation. On appeal, the Fifth Circuit reversed the District Court's improper-joinder decision and dismissal of Whole Foods. Because Whole Foods had been improperly dismissed, the Fifth Circuit concluded that the District Court lacked diversity jurisdiction, that the District Court's judgment had to be vacated, and that the case had to be remanded to state court. This Court granted certiorari to resolve a
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divide among the Courts of Appeals on whether vacatur is required in these circumstances. Held: Because the District Court's erroneous dismissal of Whole Foods did not cure the jurisdictional defect that existed when this case was removed to federal court, the Fifth Circuit correctly vacated the judgment in Hain's favor. Pp. 427–434. (a) Federal courts are courts of limited jurisdiction, and a federal court of appeals must “satisfy itself not only of its own jurisdiction, but also of that of the lower courts in a cause under review.” Mitchell v. Maurer, 293 U. S. 237, 244. In most cases, federal appellate courts assess the district court's jurisdiction based on “the state of facts that existed at the time of fling.” Grupo Datafux v. Atlas Global Group, L. P., 541 U. S. 567, 571. If the court of appeals concludes that the district court lacked jurisdiction over the case when it was fled in or removed to federal court, then the court of appeals typically must vacate any judgment on the merits. One exception to this general rule is relevant here: If a district court cures a jurisdictional defect before fnal judgment, then the court of appeals is not required to vacate that judgment even if, at some earlier point in the case, the district court lacked jurisdiction. The Court discussed this exception in Caterpillar Inc. v. Lewis, 519 U. S. 61, in which the nondiverse defendant was fully dismissed with all of the parties' consent through a partial fnal judgment under Federal Rule of Civil Procedure 54(b), leaving behind a completely diverse set of parties before trial commenced. In those circumstances, the Court held that the jurisdictional defect had been cured and the verdict could stand despite the District Court's earlier “statutory misstep” in denying the motion to remand. Id., at 73. On the other hand, the Court stated, had the jurisdictional defect not been cured and instead “lingered through judgment,” then vacatur would have been required. Id., at 76–77. Pp. 428–430. (b) The core dispute in this case is whether Whole Foods's erroneous dismissal before fnal judgment cured the jurisdictional defect that existed at the time of removal. It did not. The District Court's dismissal of Whole Foods as improperly joined was both erroneous and “[i]nterlocutory,” meaning it did “not dispose of the whole case” and “merge[d] into the fnal judgment” for “revie[w] on appeal.” Dupree v. Younger, 598 U. S. 729, 734, 735. When the Fifth Circuit reversed the District Court's error, it restored Whole Foods to the case and thus destroyed complete diversity. As a result, the jurisdictional defect “lingered through judgment” uncured and the judgment “must be vacated.” Caterpillar, 519 U. S., at 77.
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