{"id":313,"date":"2026-01-30T12:00:00","date_gmt":"2026-01-30T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=313"},"modified":"2026-01-30T12:00:00","modified_gmt":"2026-01-30T12:00:00","slug":"pratt-bonafide-provisions-cafa-jurisdiction-dismissal","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=313","title":{"rendered":"Pratt v. Bonafide Provisions \u2014 S.D. Cal. Tosses CAFA Class Action for Lack of Subject-Matter Jurisdiction"},"content":{"rendered":"
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Case<\/dt>\n
Pratt v. Bonafide Provisions, LLC<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Southern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-30<\/dd>\n
Docket No.<\/dt>\n
3:25-cv-01982<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Class Action Fairness Act, subject-matter jurisdiction, minimal diversity, amount in controversy<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

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.<\/p>\n

Bonafide moved to dismiss on other grounds, but the court raised the threshold question of subject-matter jurisdiction on its own \u2014 something federal courts must do whenever any doubt about jurisdiction arises, even if the parties do not raise it.<\/p>\n

The Court’s Holding<\/h2>\n

The court dismissed the complaint with leave to amend for two independent jurisdictional defects.<\/p>\n

First, CAFA requires “minimal diversity” \u2014 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.<\/p>\n

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.<\/em> for the principle that conclusory allegations on the amount in controversy do not establish federal jurisdiction.<\/p>\n

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.<\/p>\n

Key Takeaways<\/h2>\n