The US Supreme Court allowed a lawsuit over baby food sold by Hain Celestial Group Inc. to restart in state court, handing a victory to parents who claim their child’s autism diagnosis is tied to it.
The unanimous opinion on Tuesday affirmed a decision by the US Court of Appeals for the Fifth Circuit that vacated a federal trial judge’s order rejecting the parents’ claims because the judge never had legal jurisdiction to review the dispute.
Authored by Sonia Sotomayor, the ruling dealt with the strategic wrangling that often ensues over the venue in which a lawsuit will be heard.
The question for the justices was whether a district court’s final judgment must be vacated when an appellate court finds it mistakenly dismissed a party to the dispute that affected where the case went to trial. Justice Clarence Thomas filed a concurring opinion with the judgment that resolved a circuit split.
Sarah and Grant Palmquist say their child was diagnosed with heavy-metal poisoning and autism after eating a baby food product manufactured by Hain and purchased at a Whole Foods market.
The Palmquists sued Hain and Whole Foods in state court in Texas, which is where the Palmquists live and Whole Foods is based.
Hain, which is incorporated in Delaware, moved to transfer the case to the US District Court for the Southern District of Texas, a federal trial court.
That prompted a fight with the Palmquists, who argued the case lacked what’s known as diversity jurisdiction, which requires the case to move to federal court when the plaintiffs and defendants are from different states.
But a judge in Texas’ Southern District ruled the Palmquists “fraudulently” named Whole Foods and maintained jurisdiction over the matter. He ultimately oversaw a two-week trial where he found no scientific support to hold Hain liable.
A three-judge Fifth Circuit panel ruled the district court erred in its decision finding Whole Foods was improperly named as a defendant, which it said meant it never had jurisdiction to review the case.
The Supreme Court said the appellate decision was correct because the district judge “erroneous dismissal” of Whole Foods didn’t correct the jurisdictional problem that existed when the case was transferred to federal court.
“When the Fifth Circuit reversed the District Court’s error, it restored Whole Foods to the case and thus destroyed complete diversity. As a result, the jurisdictional defect ‘lingered through judgment’ uncured and the judgment ‘must be vacated,’” the justices said in citing its 1996 decision in Caterpiller v. Lewis.
The case is Hain Celestial Group Inc. v. Palmquist, U.S., 24-724, 11/28/25.
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