The University of New Hampshire Law Review
Abstract
Subject-matter jurisdiction is critical to every case, small or large. Establishing the court’s authority to adjudicate a present matter is tantamount to every case and for every judge. Despite the importance of properly entering and remaining in federal courts, civil procedure cases often receive far less fanfare than most others before the Supreme Court. Such was the case last term in Royal Canin U.S.A., Inc. v. Wullschleger, an overlooked case which silently reshaped removal jurisdiction jurisprudence. This Article details the importance of this quiet case. Through outlining entry into federal courts, introducing and reviewing the Eighth Circuit’s outlier—but correct—opinion that created a circuit split, and analyzing the Supreme Court’s unanimous opinion, this Article shows how the Supreme Court addressed a procedural puzzle involving the complex interplay between federal question jurisdiction, supplemental jurisdiction, and removal jurisdiction. Altogether, this Article shows how Wullschleger, a seemingly innocuous civil procedure case, fundamentally changed the removal jurisdiction landscape.
Repository Citation
Nicholas G. Glover, A Case with Bite: Royal Canin U.S.A., Inc. v. Wullschleger and the Updated Removal Jurisdiction Landscape, 24 U.N.H. L. Rev. 399 (2026).