弗雷诉HED集团等案

Plaintiff Lori Frey filed a complaint in Alabama state court alleging negligence and wantonness against HED Group Inc, RMTDD Anchor Group LLP, and its employees Preston Lee and Aaron Wade, arising from a slip and fall on business premises. Defendant Anchor Group removed the case to federal court, invoking diversity jurisdiction under 28 U.S.C. § 1332 and arguing that the Manager Defendants were fraudulently joined to destroy diversity. Frey moved to remand the case to state court. The court found that Anchor Group failed to meet its burden of proving fraudulent joinder, granted Frey's motion to remand, and directed the clerk to close the case.

The court granted Plaintiff Lori Frey's motion to remand and remanded the case to state court for further proceedings, closing the federal case.

Whether the Manager Defendants (Preston Lee and Aaron Wade) were fraudulently joined to defeat diversity jurisdiction, and whether the federal court had subject matter jurisdiction over the case.

This case illustrates the high burden defendants face when alleging fraudulent joinder to remove cases to federal court. The ruling reinforces that federal courts must carefully scrutinize removal jurisdiction and affirms plaintiffs' ability to choose their forum, particularly in personal injury actions where non-diverse defendants are named.