Patrick Lacross v. Knight Transportation Inc

With this appeal pending, we decided Ibarra v. Manheim Investments, Inc., 775F.3d 1193, No. 14-56779 (9th Cir. Jan. 8, 2015), filed simultaneously with this opinion, and addressed what proof a defendant seeking removal must produce to prove the amount in controversy requirement under the Class Action Fairness Act of 2005 (“CAFA”), 28 U.S.C. § 1332 (d), when the complaint does not include a facially apparent amount in controversy or may have understated the true amount in controversy. We held in Ibarra that when the defendant relies on a chain of reasoning that includes assumptions to satisfy its burden to prove by a preponderance of the evidence that the amount in controversy exceeds $5 million, the chain of reasoning and its underlying assumptions must be reasonable. Ibarra, 775 F.3d. at 1199. We apply our framework of analysis in Ibarra to defendants’ proof here and conclude that because defendants relied on a reasonable chain of logic and presented sufficient evidence to establish that the amount in controversy exceeds $5 million, defendants have met their burden of proof. We reverse the district court’s judgment and remand for further proceedings consistent with this…