Beneficial National Bank v. Anderson, 539 U.S. 1 (2003), established the modern complete preemption doctrine—a method of finding removal jurisdiction by way of federal defense. The decision was met immediately with a great degree of confusion and critique by scholars concerned with the doctrine’s theoretical foundation (or lack thereof) and the potential disarray in its prospective execution by lower courts.

This twenty-year retrospective tackles whether clarity has emerged in the lower courts. By analyzing all 164 circuit court cases citing to Beneficial National Bank, I find minimal moments of disagreement between circuits as to application of the doctrine. Courts have overwhelmingly declined to expand the doctrine, with growth in only three key areas: the Copyright Act, the Carmack Amendment, and the Interstate Commerce Commission Termination Act. Thus, on complete preemption, academic concerns did not come to fruition. Instead, circuit courts worked in concert and with restraint to produce stability.

These findings suggest that Supreme Court decisions involving doctrinal growth with unclear implementation may warrant less skepticism. In such instances, the Court is not merely foisting a mess upon the lower courts. Rather, it is deputizing circuit courts to use judicial reasoning to construct a sensible way forward. This Essay suggests the Supreme Court’s confidence in the circuits is well placed and posits a doctrinal-growth cycle of short-term instability preceding circuit-court development of a more-coherent whole.