Hain Celestial Group, Inc. v. Palmquist · ¶48

The Fifth Circuit vacated that merits judgment for lack of jurisdiction, but not because it thought that conducting an improper-joinder inquiry was inappropriate. 103 F. 4th 294, 302–307 (2024). It simply thought that the Palmquists possibly stated meritorious claims against Whole Foods under Texas law. See id., at 305–307. It reaffirmed that the improper-joinder doctrine allows federal courts to engage in a “Rule 12(b)(6)-type analysis” of claims against nondiverse defendants, albeit with legal ambiguities resolved in the plaintiffs' favor. Id., at 306. Federal Rule of Civil Procedure 12(b)(6) dismissals, of course, are merits determinations. See Federated Department Stores, Inc. v. Moitie, 452 U. S. 394, 399, n. 3 (1981).

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