8th Circuit Keeps Rams Class Action in Fed Court

     ST. LOUIS (CN) — A class action against the St. Louis Rams will remain in federal court, the Eighth Circuit ruled Tuesday.
     On Jan. 12, 2016, four fans sued The St. Louis Rams, The St. Louis Rams Partnership and ITB Football Company in St. Louis City court. The filing came less than 24 hours after the National Football League gave approval for the Rams to move to Los Angeles.
     The fans claimed Rams executives misled fans about the team’s intention to move from St. Louis to Los Angeles in order to induce the fans to continue to buy tickets and merchandise.
     The Rams filed a notice of removal, seeking to move the case to federal court arguing jurisdiction based on the Class Action Fairness Act (CAFA).
     Once in federal court, the plaintiffs claimed the case should be remanded back to state court arguing a lack of minimal diversity necessary to support CAFA jurisdiction
     The Rams submitted two post-removal affidavits to demonstrate diversity, but the district court expressly declined to consider the affidavits because they were not included as part of the Rams’ original motion for removal.
     The Rams appealed, arguing the federal court erred in not allowing the affidavits. The plaintiffs conceded that the federal court should have allowed the affidavits, but argued that another appropriate and sufficient reason justified remand.
     A three-judge panel of the Eighth Circuit ruled that the matter should stay in federal court.
     “A court has an independent obligation to ensure that the case is properly before it,” the court wrote in a per curiam decision. “Discovery is often necessary because jurisdictional requirements rest on facts that can be disputed, for instance, the domicile of the parties. Here, the district court abused its discretion by refusing to consider the affidavits simply on the ground that the Rams submitted the affidavits post removal. The Rams notice of removal did not need to be accompanied by a submission of evidence. The district court’s refusal to consider post removal evidence prejudiced the Rams by limiting their ability to prove their statutory right to a federal forum.”
     Judges Roger L. Wollman, Pasco M. Bowman and Lavenski R. Smith took part in the ruling.

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