CMH Homes, Inc., et al. v. Goodner, et al., No. 12-3381 (8th Cir. 2013)
Annotate this CasePlaintiffs filed a putative class action suit against CMH Homes, Vanderbilt and others in state court. The companies subsequently filed a petition in the district court alleging that plaintiffs' claims were subject to mandatory arbitration. The district court dismissed the petition. The companies argued that the district court erred by concluding that it lacked diversity jurisdiction. The court concluded that the district court correctly reasoned that Vaden undermined Advance America and required the court's departure from that precedent. Following the Vaden approach, the district court properly looked through the arbitration petition to the state court complaint to determine the amount in controversy. Nonetheless, the court remanded for the district court to calculate an amount in controversy and to determine on that basis whether it had jurisdiction over the putative class action under 28 U.S.C. 1332(d)(2).
Court Description: Civil case - Federal Arbitration Act. Here plaintiffs filed a putative class action in state court raising claims under the Arkansas Deceptive Trade Practices and Unfair Practices acts, and defendants removed the case to federal court and asked the court to compel arbitration of the claims; when asked by plaintiffs to remand the case to state court and dismiss the arbitration petition for lack of subject matter jurisdiction, the district court properly looked through the arbitration petition to the state court complaint to determine the amount in controversy; however, the case must be remanded for the district court to calculate an amount in controversy and to determine whether it has jurisdiction over the putative class action under 28 U.S.C. Sec. 1332(d)(2)
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