Doyle v. OneWest Bank

In class action suits, the citizenship of the plaintiff class must be determined based on the complaints being filed in the proper court, and not based on subsequent motions filed after removal.

Geraldine Doyle and Kuda Mujeyi were involved in a class action suit against several defendants, including OneWest Bank, FSB. One of the defendants removed the case to district court. While in district court, the parties agreed to sever some of the involved claims. Doyle then amended her complaint to reflect the severance of the earlier claims and then moved to remand the action back to California State Court. The district court granted Doyle’s motion based on the citizenship of the plaintiff class from the amended complaint. On appeal, the Ninth Circuit explained that granting the motion based on the amended complaint was an error. The panel determined that the district court should have made its determination based on the initial complaint. The panel thus vacated the motion and remanded the case back to district court. VACATED and REMANDED.