Overview
- The unanimous opinion by Justice Sonia Sotomayor affirms the Fifth Circuit and holds the district court lacked jurisdiction when the case was removed.
- The suit by Sarah and Grant Palmquist alleges their child was harmed by heavy metals in Hain baby food purchased at Whole Foods, and the merits remain unresolved.
- The district court had dismissed Whole Foods as improperly joined and later found the Palmquists failed to prove causation, but the Fifth Circuit vacated and ordered remand.
- The Supreme Court concluded the erroneous dismissal of Whole Foods did not cure the jurisdictional defect, distinguishing the Caterpillar exception.
- Justice Clarence Thomas concurred to question the century‑old improper‑joinder doctrine and urged the Court to revisit it in a future case.