519 U.S. 61 (1996)
Caterpillar Inc. v.
Did the presence of a non-diverse defendant preclude removal of the case from state court to federal court under the complete diversity requirement?
The Supreme Court held that a case may be removed to federal court if there is complete diversity between the parties at the time of removal, and that the presence of a non-diverse defendant does not automatically defeat removal if the defendant is fraudulently joined. The Court emphasized that the removal statute must be construed in favor of the defendant's right to remove, and that the determination of diversity is based on the parties' citizenship at the time of removal.
The Supreme Court held that Caterpillar's removal of the case to federal court was proper, as complete diversity existed despite the presence of a non-diverse defendant. The Court ruled that the non-diverse defendant was fraudulently joined, and thus did not defeat the federal court's jurisdiction. The Court's decision reinforced the principle that removal should be favored when the statutory criteria are met, and clarified the standards for determining fraudulent joinder.
Caterpillar Inc. v. Lewis is a landmark case that has had a lasting impact on the interpretation of removal jurisdiction and complete diversity in civil procedure. The case is frequently cited in subsequent litigation involving removal issues, particularly in discussions of fraudulent joinder and the standards for determining diversity jurisdiction. Law students and practitioners alike must understand the principles established in this case, as they are foundational to navigating the complexities of federal jurisdiction and the removal process.