Hain Celestial Group, Inc. v. Palmquist · ¶47

Although the parties in this case were not completely diverse, the District Court exercised jurisdiction based on the doctrine of “improper joinder.” Under that doctrine, federal courts exercise jurisdiction over cases that originally involved nondiverse defendants by first deeming the claims against those nondiverse defendants sufficiently weak on the merits and then dismissing them. See, e. g., International Energy Ventures Mgmt., L.L.C. v. United Energy Group, Ltd., 818 F. 3d 193, 205–209 (CA5 2016). Here, the Palmquists, Texas citizens, sued both an out-of-state defendant, Hain Celestial Group, and a Texas defendant, Whole Foods. The District Court therefore lacked jurisdiction over the case when it was removed to federal court. The District Court nonetheless proceeded to dismiss Whole Foods based on its merits assessment that there was not a “reasonable basis to predict that [the…

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