Hain Celestial Group, Inc. v. Palmquist · ¶34

Hain also appeals to efficiency, arguing that it would be wasteful to send this case back to state court for a new trial. This argument also fails. To be sure, Caterpillar recognized that “considerations of finality, efficiency, and economy become overwhelming” after “a diversity case has been tried in federal court.” 519 U. S., at 75. Those considerations, however, were relevant only to excusing noncompliance with the removal statute's requirement “that there be complete diversity at the time of removal” after a jurisdictional defect had been properly and finally cured. Grupo Datafux, 541 U. S., at 574. As to the jurisdictional requirement itself, Caterpillar held that an uncured jurisdictional defect means that “the judgment must be vacated,” 519 U. S., at 76–77, regardless of how efficient it might be to leave the judgment in place. That the parties may need to litigate a new trial…

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