Gale v. Chicago Title Insurance Co., No. 17-3497 (2d Cir. 2019)Annotate this Case
The Second Circuit affirmed the district court's judgment, holding that when jurisdiction‐granting class‐action allegations are removed from a complaint, a district court is divested of Class Action Fairness Act (CAFA) jurisdiction and the action must be dismissed. In this case, a Connecticut attorney filed suit against a group of title insurance companies for allegedly violating a Connecticut law that allows only Connecticut attorneys to act as title agents in the state. After plaintiffs amended the complaint to remove all class action allegations, the district court concluded that the withdrawal of the class‐action allegations divested it of CAFA jurisdiction and dismissed the amended complaint.