Hain Celestial Group, Inc. v. Palmquist
Justia · Docket · oyez.org
Argued on Nov 4, 2025.
Petitioner: The Hain Celestial Group, Inc., et al.
Respondent: Sarah Palmquist, Individually and as Next Friend of E.P., a Minor.
Advocates:
- Sarah E. Harrington (for the Petitioners)
- Russell S. Post (for the Respondents)
Facts of the case (from oyez.org)
Grant and Sarah Palmquist’s son Ethan developed normally until about 30 months of age, when he experienced sudden and severe developmental regression, including cognitive, behavioral, and physical impairments. He was later diagnosed with a range of conditions—some physical, like seizures and hypotonia, and others mental, like autism and neurocognitive disorders. Tests also revealed high levels of toxic heavy metals in Ethan’s system, which some physicians attributed to heavy-metal poisoning. The Palmquists linked his symptoms to his nearly exclusive consumption of Earth’s Best Organic baby food—manufactured by Hain Celestial Group, Inc. and sold by Whole Foods Market, Inc.—from infancy through toddlerhood. In 2021, a U.S. House Oversight Committee report revealed that Hain’s baby foods contained high levels of arsenic, lead, cadmium, and mercury and that Hain had not tested final products for such contaminants until 2019.
In 2021, the Palmquists sued Hain and Whole Foods in Texas state court, raising various state-law claims. Hain removed the case to federal court, alleging that Whole Foods had been improperly joined to defeat diversity jurisdiction. The district court agreed, dismissed Whole Foods, and denied the Palmquists’ motion to remand. It later granted judgment as a matter of law for Hain during trial. On appeal, the U.S. Court of Appeals for the Fifth Circuit reversed, holding that the Palmquists had adequately stated claims against Whole Foods, defeating diversity jurisdiction. It vacated the judgment and remanded the case with instructions to return it to state court.
Question
Must a federal court’s final judgment be set aside if the case did not have complete diversity when it was removed from state court, and can a plaintiff block diversity jurisdiction by updating the complaint after removal to include a valid claim against a nondiverse defendant?
