Eleventh Circuit: Joan Simring v. GreenSky, LLC

 District court remand to state court under the local controversy exception to the class action statute is reviewable despite the ouster clause of the statute, since the remand is neither for a lack of subject matter jurisdiction nor due to a procedural defect.  The appeal didn't require an authorization of permissive appeal, as the remand order is sufficiently final.

Despite the stipulated limit to the damages by the lead plaintiff, the deft's estimate of relief across the class prevails, since the lead plaintiff has no authority to bind the relief granted the class; the relief therefore exceeds the limit for the local controversy exception.

For purposes of determining residency of class members, only the explicit definition of the class can limit the class to a certain state, and the plaintiff has the burden of establishing the required fraction of in-state class members.

Joan Simring v. GreenSky, LLC