Carter_v_CIOX_Health_LLC, 2017 WL 2334886 (W.D.N.Y. May 30, 2017).
When denying a defendant’s request to remand a putative class action for lack of subject matter jurisdiction under CAFA, a district court in New York educates the parties on the origins, purposes, and applicability of the local controversy exception and explains when the “no other action” element of the local controversy exception applies and why it exists.
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