Wullschleger v. Royal Canin U.S.A., Inc., No. 19-2645 (8th Cir. 2020)
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Plaintiffs filed a putative class action alleging that defendants deceived plaintiffs into believing their products were approved by the FDA. After the district court remanded the case back to state court, the Eighth Circuit granted defendants' petition for review under 28 U.S.C. 1453(c)(1), limiting review to the issue of federal question jurisdiction.
The court held that federal question jurisdiction exists in this case, because plaintiffs rely explicitly on federal law throughout their pleadings and their prayer for relief invokes federal jurisdiction where it seeks injunctive and declaratory relief that necessarily requires the interpretation and application of federal law, including the Food Drug and Cosmetic Act. Therefore, based on the allegations in the complaint and relief sought, the court found that a federal issue surrounding the state law claims is necessarily raised, actually disputed, substantial, and capable of resolution in federal court without disrupting the federal-state balance approved by Congress. Accordingly, the court vacated and remanded for further proceedings.
Court Description: [Erickson, Author, with Loken and Benton, Circuit Judges] Civil case - Class Actions. In action alleging defendants' marketing of their premium pet foods violated the Missouri Merchandising Practices Act, Missouri antitrust laws and Missouri unjust enrichment law, the district court erred in remanding the matter to state court for lack of subject matter jurisdiction; plaintiffs rely explicitly on federal law throughout their pleadings, and their prayer for relief invokes federal jurisdiction because it seeks injunctive and declaratory relief that necessarily requires the interpretation and application of federal law, including the Food Drug and Cosmetic Act; as a result, based on the allegations of the complaint and the relief sought, a federal issue surrounding the state law claims is necessarily raised, actually disputed, substantial and capable of resolution in federal court without disturbing the federal-state balance approved by Congress.
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