City of St. Louis v. American Tobacco Company, Inc.

After seeing false or misleading advertisements and then smoking addictive tobacco products, indigent individuals in Missouri developed tobacco-related illnesses like lung cancer and emphysema. The individuals, who relied on Medicaid for health insurance, needed medical treatment for their illnesses. The City of St. Louis and numerous hospitals and medical-care entities in Missouri (collectively, the healthcare providers) (plaintiffs) provided necessary treatment but incurred unreimbursed costs. In state court, the healthcare providers sued American Tobacco Company, Inc., and companies that manufactured and distributed tobacco products (collectively, the tobacco companies) (defendants), alleging the factual premises for claims of nuisance, products liability, and restitution, among others. A group of the tobacco companies that solely distributed tobacco products (the distributors) were all citizens of Missouri. The tobacco companies removed the case to federal district court, arguing that diversity jurisdiction existed despite the inclusion of the distributors as defendants because the distributors were wrongfully joined in the action for the purpose of insuring state-court jurisdiction. The distributors posited that the healthcare providers could not possibly state a cause of action against them. The healthcare providers filed a motion to remand the matter back to state court, arguing that they had sufficiently alleged a claim for restitution against the distributors.