Wind v. Eli Lilly & Co.
Plaintiff Janice Wind sued pharmaceutical companies for DES-related injuries in New York state court in 1986. Defendants Eli Lilly & Company and The Upjohn Company removed the case to federal court in February 1993, citing complete diversity after a claimed settlement with E.R. Squibb & Sons, Inc. Plaintiff moved to remand, asserting no settlement occurred and that removal was barred by the one-year limit under 28 U.S.C. § 1446(b), amended in 1988. The court granted the plaintiff's motion, remanding the case to state court and applying the one-year removal limitation retroactively to the pending action. It found no manifest injustice in applying the procedural change and did not address other jurisdictional arguments.