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Woods v. Standard Ins. Co. 771 F.3d 1257 (10th Cir. Nov. 10, 2014) 

Nov 10, 2014

State employees, representing a class of New Mexico state and local government employees, commenced action in state court alleging that they paid for insurance coverage through payroll deductions and premiums pursuant to a policy issued by their insurer, but did not receive the coverage for which they paid. Defendants removed to federal court under the Class Action Fairness Act (CAFA). The district court remanded to state court, finding that the local controversy exception to CAFA required it to decline jurisdiction. The Tenth Circuit reversed. Although plaintiffs could not satisfy the “local defendant” requirement of CAFA’s local controversy exception (28 U.S.C. § 1332(d)(4)(A)) simply by naming the insurance company’s local agent as a defendant, the local agent’s conduct did not form a significant basis for the plaintiff’s claims, and the plaintiffs did not seek significant relief from her.