Sonna Griffiths, Jack Licha, Steven Elli, Pamela Hagen, Cynthia Wade, April Capello, Joseph Jordan, Donna Thomas, Julie Goodwin, Daniel Ferguson, and Sarah Speelman, et al. v. Kootenai Health, Inc.

Summary

The United States District Court for the District of Idaho declined to exercise jurisdiction under the Class Action Fairness Act’s mandatory and discretionary home-state exceptions. The court found that the parties failed to provide competent evidence showing that the putative class included sufficient non-Idaho citizens, dismissed the consolidated class action without prejudice, denied the pending motion to dismiss as moot, and remanded one case that had been removed from state court.

Holdings

1. When the court raises CAFA abstention sua sponte and the parties seek to retain the federal forum, the parties must provide competent evidence sufficient to establish by a preponderance of the evidence that the action falls outside the mandatory home-state exception. Mailing addresses and residence, without evidence of domicile, do not satisfy that burden.
2. Even if mandatory declination were not required, the court would decline CAFA jurisdiction under the discretionary home-state exception because the totality of the circumstances showed an Idaho-centered controversy.
3. When consolidated cases include both cases originally filed in federal court and a case removed from state court, the federal cases may be dismissed without prejudice after CAFA abstention, but the removed case must be severed and remanded to state court.

Questions Presented

1. Whether the court should decline to exercise CAFA jurisdiction under the mandatory home-state exception, 28 U.S.C. § 1332(d)(4)(B), because the parties failed to show by a preponderance of the evidence that the putative class was sufficiently non-Idaho-centered.
2. Whether the court should alternatively decline to exercise CAFA jurisdiction under the discretionary home-state exception, 28 U.S.C. § 1332(d)(3), based on the totality of the circumstances.
3. Whether the consolidated cases should be dismissed without prejudice or remanded, given that one consolidated case had been removed from state court.
4. Whether the pending motion to dismiss should be decided after the court declined to exercise CAFA jurisdiction.

Disposition

other