Alejandra Chaisson v. University of Southern California

BACKGROUND

On July 14, 2020, plaintiffs Alejandra Chaisson and Grace Chong (collectively, “plaintiffs”) filed a putative class action complaint in the Los Angeles County Superior Court (“state court”) against the University of Southern California (“defendant” or “USC”), related to late fees charged by USC. (See Dkt. 1, Notice of Removal (“NOR”) at ¶¶ 1-2); (Dkt. 1-3, Complaint). On May 11, 2021, plaintiffs filed the operative Second Amended Complaint (“SAC”), which asserted various state law claims, and “maintained the same class definition as the original Complaint: All current or former students of USC who reside in California and paid or were charged one or more Late Fees imposed by Defendant within the past four years.” (Dkt. 1, NOR at ¶ 20) (internal quotation marks omitted); (Dkt. 2-3, SAC at ¶ 25). On June 22, 2022, plaintiffs filed a motion for class certification, which sought to certify a nationwide class rather than the more narrow California-only class set forth in the SAC (and prior iterations of the complaint). (Dkt. 1 NOR at ¶¶ 26, 33). On the basis of the motion to certify, USC removed the action pursuant to CAFA. (Id. at ¶¶ 34-36,…