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Justice Thomas Urges Review of Improper-Joinder Doctrine

2/25/2026

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Story summary
  • On February 24, 2026, Supreme Court Justice Clarence Thomas wrote a concurring opinion urging the court to revisit the improper-joinder doctrine.
  • The move followed a unanimous ruling in Hain Celestial Group, Inc. v. Palmquist that Whole Foods was improperly dismissed from a suit over heavy-metal poisoning in baby food.
  • Thomas argued that federal courts should not dismiss nondiverse parties based on merits because this conflicts with Congress's diversity limits.