Since citizenship for purposes of the local controversy exception and discretionary exception to the class-action statute is based on current domicile, court clearly erred in using demographic data of past residence in a care facility as sufficient proof of citizenship. Commonsense inference that locals tend to enter nearby homes and that few of those over 65 move out of Florida are insufficient.
Plaintiff satisfied the "significant defendant" standard even absent a showing of means, since the statute requires a party against whom significant relief may be sought, not a party against whom a significant judgment may be recovered.
A corporation liable through vicarious liability can be a primary defendant for purpose of the CAFA discretionary exception.class