Hain Celestial Group, Inc. v. Palmquist · ¶37

In Newman-Green, Inc. v. Alfonzo-Larrain, 490 U. S. 826 (1989), this Court held that, in appropriate circumstances, courts may use Rule 21 “to dismiss a dispensable nondiverse party.” Id., at 833, 837. To do so, courts must “carefully consider whether the dismissal of a nondiverse party will prejudice any of the parties in the litigation,” as “[i]t may be that the presence of the nondiverse party produced a tactical advantage for one party or another.” Id., at 838.

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