Atwood v. Peterson, No. 16-1152 (8th Cir. 2019)Annotate this Case
Plaintiff filed a class action in state court against Walgreens and others, claiming that the Walgreens Balance Rewards program violated Arkansas's statutory prohibition on price discrimination in the sale of manufactured products. After defendants removed to federal court under the Class Action Fairness Act of 2005 (CAFA), the district court denied remand and granted defendants' motion to dismiss.
The Eighth Circuit affirmed, holding that the district court did not err by finding that the district managers were not significant defendants under CAFA, and in concluding that they had been fraudulently joined in an attempt to defeat diversity jurisdiction. In light of the court's determination that the district managers' conduct did not form a significant basis for plaintiff's claim, the court held that plaintiff failed to meet his burden of establishing that the local controversy exception to CAFA jurisdiction applies. The court rejected plaintiff's argument that the district court was without jurisdiction to decide the merits of his case because he did not have Article III standing. Finally, the court rejected plaintiff's claim that the district court erred in dismissing his complaint with prejudice.