Spencer v. Specialty Foundry Products Inc., No. 19-14427 (11th Cir. 2020)
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Plaintiffs and 229 former workers at the Grede Foundry filed suit against ten entities that manufactured, sold, supplied, and distributed the products they believe harmed them. After defendants removed the case to federal court, the district court granted plaintiffs' motion to remand to state court.
The Eleventh Circuit vacated the district court's grant of plaintiffs' motion to remand, holding that the local event exception to the Class Action Fairness Act's grant of federal jurisdiction applies to any continuing set of circumstances in a single location, regardless of when and how the harm came about. The court held that "an event or occurrence" refers to a series of connected, harm-causing incidents that culminate in one event or occurrence giving rise to plaintiffs' claims. In this case, the complaint does not allege a continuous, related course of conduct culminating in one harm-causing event or occurrence, and thus it does not fall within the local event exception. Accordingly, the court remanded for further proceedings.
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