Bridewell-Sledge v. Blue Cross of CA

The district court, in evaluating whether it had jurisdiction under the Class Action Fairness Act of 2005, 28 U.S.C. 1332(d), over the removed action, analyzed this consolidated case as though it remained two separate class actions, and concluded that CAFA’s local controversy exception applied to the first-filed class action, Bridewell-Sledge v. Blue Cross of California, but that the exception did not apply to the second-filed class action, Crowder v. Blue Cross of California. The court held that it was improper for the district court to view Bridewell-Sledge and Crowder as two separate class actions after they had been consolidated by the state court. In this case, the Bridewell-Sledge/Crowder consolidated class action should have been viewed by the district court as a single class action when evaluating jurisdiction under CAFA. Once it is recognized that the two cases became one, it is clear that CAFA’s local controversy exception applies to the consolidated class action, and, therefore, the district court was required to remand the entire Bridewell-Sledge/Crowder consolidated class action to state court. View "Bridewell-Sledge v. Blue Cross of CA" on Justia Law