Diana Satterlee v. Allstate Fire and Casualty Company; and Monica Baker Agency, Inc.

Summary

The court grants Plaintiff Diana Satterlee’s motion to remand an insurance dispute to the District Court of Cleveland County, Oklahoma. It holds that Allstate failed to establish with complete certainty that the nondiverse insurance agency was fraudulently joined, so federal subject-matter jurisdiction was lacking.

Holdings

1. Allstate failed to establish with complete certainty that Plaintiff could not state a cause of action against Monica Baker Agency in Oklahoma state court; therefore, Baker was not shown to have been fraudulently joined.
2. Because Allstate failed to establish fraudulent joinder of the nondiverse defendant, complete diversity was absent and the federal court lacked subject-matter jurisdiction.

Questions Presented

1. Whether Allstate established that Monica Baker Agency was fraudulently joined because Plaintiff had no possibility of stating a claim against the agency under Oklahoma law.
2. Whether the absence of established fraudulent joinder required remand for lack of complete diversity and subject-matter jurisdiction.

Disposition

remanded