Caterpillar Inc. v. Lewis
136 L. Ed. 2d 437 · Supreme Court of the United States · 1996
Facts
Lewis, a Kentucky resident, sued Caterpillar and Whayne Supply (also Kentucky) in state court for personal injuries. Caterpillar removed the case to federal court, despite the lack of complete diversity due to Whayne Supply's presence. Lewis's motion to remand was denied, but Whayne Supply was later dismissed after settlement, establishing complete diversity before trial and judgment for Caterpillar.
Issue
Is the absence of complete diversity at the time a case is removed to federal court fatal to the ensuing federal court adjudication, even if the jurisdictional defect is cured before judgment and the plaintiff timely objected to the removal?
Holding
No, a district court's error in failing to remand a case improperly removed is not fatal to the ensuing adjudication if federal jurisdictional requirements, specifically complete diversity, are met at the time judgment is entered. The judgment for Caterpillar was therefore valid.
Rule
When a case is improperly removed to federal court due to a lack of complete diversity, but the nondiverse party is dismissed and complete diversity is established before trial and judgment, the federal court's judgment will stand, even if the plaintiff timely objected to the initial removal. Considerations of finality, efficiency, and economy outweigh the initial procedural error.
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