McAllister v. The St. Louis Rams, LLC, No. 4:16-cv-00172 (E.D. Mo. Feb. 12, 2018).
In this action, while remanding a case to state court, a district court in Missouri found that the plaintiffs’ burden of proof, as the party invoking the local controversy exception, is by a “preponderance” or more than 50% of the evidence.