SABRINA ROPPO, individually and on behalf of others similarly situated, Plaintiff-Appellant, v. TRAVELERS COMMERCIAL INSURANCE CO., et al., Defendants-Appellees., 869 F.3d 568

Summary

HOLDINGS: [1]-Allegations in the complaint operative at the time of removal, along with the insurance company's disclosure of the relevant umbrella policy limits, were sufficient for the district court to conclude that it had subject matter jurisdiction under the Class Action Fairness Act; [2]-The "local controversy" exception also did not require remand: the insurance company was the "primary" defendant in this action; [3]-Moreover, plaintiff's Racketeer Influenced and Corrupt Organizations Act (RICO) allegations provided an independent basis for federal jurisdiction; [4]-Finally, the court did not err in dismissing the third amended complaint because it insufficiently pled claims of fraudulent misrepresentation, negligent misrepresentation, and negligence, as well as violations of the Illinois Insurance Code, the Illinois Consumer Fraud and Deceptive Business Practices Act, and RICO.