Caterpillar Inc. v. Lewis
United States Supreme Court
519 U.S. 61 (1996)
Lewis (plaintiff) sued Caterpillar and Kentucky-based Whayne Supply (defendants) in state court over a bulldozer injury; after Liberty Mutual intervened as a plaintiff and Lewis settled with Whayne, Caterpillar removed the case to federal court on diversity grounds, over Lewis's objection that Liberty Mutual's claims against Whayne remained unsettled, meaning Whayne was technically still a defendant defeating complete diversity at the time of removal. The federal court granted removal; Liberty Mutual and Whayne settled shortly after, and a federal jury ultimately ruled against Lewis, but the court of appeals vacated the judgment, finding removal improper because Whayne was still a party when removal was granted, and the Supreme Court granted certiorari.
Whether a district court's error in prematurely removing a case from state to federal court, before complete diversity jurisdiction technically existed, requires vacating a judgment when complete diversity did exist by the time that judgment was actually entered.