Summary
The court denied Plaintiff Michael Turner’s motion to remand, holding that Defendant Randy L. John was fraudulently joined and should be disregarded for purposes of diversity jurisdiction. The court dismissed Turner’s claims against John without prejudice and vacated the stay, allowing the action against State Farm to proceed in federal court.
Court
United States District Court for the Western District of Oklahoma
Jurisdiction
United States District Court for the Western District of Oklahoma
Decision date
March 30, 2026
Docket number
CIV-25-823-G
Disposition
dismissed
Questions Presented
- Whether State Farm established actual fraud in Turner's pleading of jurisdictional facts.
- Whether Turner had any possibility of recovery against nondiverse defendant Randy L. John on a negligent-procurement claim under Oklahoma law.
- Whether Turner had any possibility of recovery against John for constructive fraud or negligent misrepresentation under Oklahoma law.
- Whether John's alleged fraudulent joinder permitted the court to disregard his Oklahoma citizenship and deny the motion to remand.
Holdings
- The similarity of Turner's allegations to allegations in other cases and the number of cases filed by his counsel did not, standing alone, establish actual fraud in the pleading of jurisdictional facts.
- Turner did not state a potentially viable negligent-procurement claim because John procured a full replacement-cost policy providing coverage for weather-related losses, Turner did not allege that he requested additional specific coverage that John failed to obtain, and the alleged injury arose from State Farm's later claims adjustment and coverage decisions rather than from procurement of the policy.
- Turner did not state a potentially viable constructive-fraud or negligent-misrepresentation claim against John because he identified no affirmative procurement-stage statements supporting the claim, failed to establish a duty to disclose the alleged State Farm claims-handling scheme, and failed to allege a causal nexus between John's procurement conduct and the claimed damages.
- John was fraudulently joined because State Farm established that Turner could not possibly recover against him on either asserted claim. John's Oklahoma citizenship was therefore disregarded, complete diversity existed between the relevant parties, and the motion to remand was denied.
Court Document
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