[24-724] Hain Celestial Group, Inc. v. Palmquist

Nov 4, 2025

Mr. Post (Counsel for Respondent Palmquist)

Ms. Harrington (Counsel for Petitioner Hain Celestial Group)

In this discussion, Ms. Harrington represents Hain Celestial Group, emphasizing the importance of preserving final judgments despite a non-diverse defendant's dismissal. Mr. Post counters by asserting that federal courts cannot gain jurisdiction through error and stresses the implications of such removals. Topics span jurisdictional defects, the fairness of dismissals, and the plaintiff's forum choice rights. The debate reveals intricate legal principles and the potential consequences of each argument on future cases.

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INSIGHT

Final Judgment Depends On Case At Judgment

Federal final judgments stand if the court had jurisdiction over the case as it existed at final judgment.
Ms. Harrington argued Caterpillar supports preserving judgments when the non-diverse defendant was treated as never having been in federal court.

ADVICE

Use Early Certification To Fix Jurisdiction Risk

Seek interlocutory review (Rule 54(b) or 1292(b)) if you fear a dismissed party is indispensable and could affect jurisdiction.
Ms. Harrington suggested plaintiffs worried about jurisdictional risk can pursue those early certifications.

INSIGHT

Fraudulent Joinder Leaves Parties Subject To Review

Fraudulent-joinder rulings function as interlocutory determinations that keep the non-diverse party 'in the case' subject to appeal.
Mr. Post argued such parties remain part of the litigation until an appellate court affirms dismissal.

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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?