Unreported / Non-Citable
Background
George Pratt filed a putative class action in the Southern District of California against Bonafide Provisions, LLC, a California-based food company. He invoked federal jurisdiction under the Class Action Fairness Act (“CAFA”), the federal statute that allows certain large class actions to be heard in federal court if specific requirements are met.
Bonafide moved to dismiss on other grounds, but the court raised the threshold question of subject-matter jurisdiction on its own — something federal courts must do whenever any doubt about jurisdiction arises, even if the parties do not raise it.
The Court’s Holding
The court dismissed the complaint with leave to amend for two independent jurisdictional defects.
First, CAFA requires “minimal diversity” — at least one plaintiff and one defendant must be citizens of different states. Pratt is a California resident, and Bonafide is alleged to have its principal place of business in Carlsbad, California. Because both sides are California citizens, the minimal-diversity test is not met. The court noted that whether Bonafide is a limited liability company or a corporation does not change the result: both forms are treated as California citizens given the allegations.
Second, CAFA requires more than $5 million in controversy in the aggregate, exclusive of interest and costs. The complaint contained only a conclusory recitation that the amount-in-controversy threshold was satisfied. Under Ninth Circuit law, that is not enough. The court cited Matheson v. Progressive Specialty Insurance Co. for the principle that conclusory allegations on the amount in controversy do not establish federal jurisdiction.
Bonafide’s separate motion to dismiss was denied as moot because the court had no jurisdiction to consider it. Pratt was given until February 13, 2026, to file an amended complaint that cures both defects.
Key Takeaways
- Federal courts must independently police subject-matter jurisdiction in CAFA cases, even when no party challenges it. Plaintiffs cannot assume that filing under CAFA will go unchallenged just because the defendant moves to dismiss on other grounds.
- CAFA’s “minimal diversity” requirement still demands that at least one plaintiff and one defendant come from different states. A California plaintiff suing a California-headquartered company in California cannot use CAFA without a non-California class member or co-defendant of diverse citizenship.
- Citing the $5,000,000 jurisdictional minimum is not enough on its own. A complaint must include facts that plausibly show how the asserted damages, statutory penalties, or restitution add up across the class to that amount.
- The form of a corporate defendant — LLC versus corporation — usually does not matter for CAFA citizenship purposes; both are treated as citizens of the state of their principal place of business (and, for corporations, of incorporation).
Why It Matters
This decision is a useful reminder for plaintiffs’ counsel filing California-based class actions: CAFA is not a shortcut into federal court when both sides are based in the same state. Many California companies face California-based plaintiffs, and lawyers sometimes treat federal court as a default forum without first walking through the diversity and amount-in-controversy elements that CAFA demands.
For California businesses, the case is a low-cost reminder that the federal courthouse door is not automatic in class actions. Defendants who would prefer to litigate in state court — or who simply want to push back on a plaintiff’s choice of forum — should consider raising jurisdictional defects early. Even where the defendant does not raise them, the court is required to do so if the complaint does not affirmatively show the elements of CAFA jurisdiction.