Abraham Natural Foods Corp. v. Mount Vernon Fire Insurance
Plaintiff Abraham Natural Foods Corp. initiated an action seeking a declaration that Mount Vernon Fire Insurance Company was obligated to indemnify and defend it in a wrongful death suit. The case was removed to federal court based on diversity jurisdiction. Plaintiff later amended its complaint to add several non-diverse defendants, including Modern Insurance Agency and Ok Z. Kim. Defendants moved to dismiss for lack of subject matter jurisdiction, arguing that the joinder of non-diverse parties destroyed diversity. Plaintiff cross-moved to remand the case to state court. The Court denied the motion to dismiss and granted the motion to remand, finding that the joinder of Modern was permissible under Rule 20 and legitimate, thus requiring remand under 28 U.S.C. § 1447(e).