Wright Transportation, Inc. v. Pilot Corporation, 2016 U.S. App. LEXIS 20937

Wright Transportation (Alabama) sued Pilot and certain employees in federal court alleging RICO and multiple state-law claims as a nationwide class under CAFA and other jurisdictional theories.
An earlier nationwide class settlement in a different lawsuit (E.D. Ark.) eliminated Wright’s ability to pursue the class claims; the Alabama district court dismissed the class claims after that settlement.
The federal RICO claims were dismissed on pleading grounds; later discovery revealed Pilot had an Alabama citizen-member such that diversity never existed.
Wright moved to dismiss the remaining state-law claims without prejudice to refile in state court; Pilot argued CAFA originally conferred federal jurisdiction that survives the later loss of class status.
The district court declined to exercise jurisdiction, treating the dismissed CAFA/class claims as removing original jurisdiction and relying on supplemental-jurisdiction principles to dismiss the state claims.
The Eleventh Circuit reversed, holding CAFA conferred original jurisdiction at filing and that jurisdiction continued despite post-filing events that eliminated the class.

Issue	Plaintiff's Argument (Wright)	Defendant's Argument (Pilot)	Held
Whether CAFA-based original federal jurisdiction survives after class claims are dismissed post-filing	CAFA jurisdiction ended when the district court dismissed the class claims; therefore federal jurisdiction no longer exists for the remaining state-law claims	CAFA conferred original jurisdiction at the time of filing and that jurisdiction persists for the life of the case despite later loss of class status	Reversed: CAFA conferred original jurisdiction at filing and it survives post-filing events that eliminate the class claims
Whether the district court should have relied on supplemental jurisdiction instead of CAFA	The court correctly dismissed under 28 U.S.C. §1367 because it had dismissed the claims giving rise to original jurisdiction	CAFA, having conferred original jurisdiction over all pleaded claims, made supplemental jurisdiction analysis unnecessary	Held that supplemental jurisdiction analysis was unnecessary because CAFA provided continuing original jurisdiction over the state-law claims

Vega v. T-Mobile USA, Inc., 564 F.3d 1256 (11th Cir. 2009) (post-removal events like non-certification do not divest CAFA jurisdiction)
Cunningham Charter Corp. v. Learjet, Inc., 592 F.3d 805 (7th Cir. 2010) (CAFA jurisdiction does not depend on certification; distinguishes frivolous CAFA invocations)
Louisiana v. American National Property & Casualty Co., 746 F.3d 633 (5th Cir. 2014) (collecting circuits holding post-removal events do not oust CAFA jurisdiction)
In Touch Concepts, Inc. v. Cellco Partnership, 788 F.3d 98 (2d Cir. 2015) (CAFA jurisdiction can survive amendment that abandons class claims in some contexts)
Brown v. Mortgage Electronic Registration Systems, Inc., 738 F.3d 926 (8th Cir. 2013) (example of exercising supplemental jurisdiction after CAFA claims dismissed where only some claims were CAFA-qualifying)
Rockwell International Corp. v. United States, 549 U.S. 457 (2007) (when plaintiff files in federal court and voluntarily amends to eliminate jurisdictional allegations, courts look to the amended complaint)
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (courts have independent obligation to determine subject-matter jurisdiction)