Caterpillar Inc. v. Lewis

Facts

Plaintiff Lewis, a Kentucky resident, sued Whayne Supply company and Defendant Caterpillar, a Delaware corporation, for injuries he sustained while operating a bulldozer manufactured by Caterpillar. After the suit was filed Liberty Mutual, a Massachusetts corporation, intervened as a plaintiff. Before trial Plaintiff Lewis settled with Whayne. Defendant Caterpillar then filed a motion to remove the case to federal court based on diversity of citizenship. Plaintiff Lewis argued that diversity jurisdiction was not appropriate because Plaintiff Liberty Mutual had not settled its claims with Whayne and therefore diversity was not satisfied. The district court granted Defendant Caterpillar’s request for removal. After removal, Liberty Mutual and Whayne settled. After a jury trial Plaintiff Lewis’s claim against Defendant Caterpillar was dismissed. The court of appeals vacated the judgement of the district court, holding that the district court should not have granted removal because Whayne was still a party at the time. The Supreme Court of the United States granted certiorari.