7th Cir.

Tushawn Craig v. City of Richmond, Indiana

June 18, 2026 ·26-1864 ·Panel Decision ·Brennan · By Raj Patel

The Seventh Circuit affirmed a district court order remanding a mass action to state court. The court held that the Class Action Fairness Act's local event exception is jurisdictional and that all claims arose from a single industrial fire.

Background

An industrial facility in Richmond, Indiana, burned for over a week, emitting hazardous gases. One hundred fifty plaintiffs sued property owners in state court for injuries and damages. Defendants removed the case to federal court as a mass action under the Class Action Fairness Act. The district court remanded the case to state court, finding the local event exception applied.

The court’s reasoning

The court held that the local event or occurrence exception is jurisdictional because it defines the term mass action, which determines removability. The court found the fire was a single event or occurrence from which all claims arose, regardless of underlying causes or multiple defendants.

We hold that the exception is jurisdictional, and that all claims in this action arise from the local fire event, so we affirm.

Tushawn Craig v. City of Richmond, Indiana, No. 26-1864 (7th Cir. June 18, 2026)

What it means going forward

The ruling clarifies that the local event exception is jurisdictional, allowing courts to raise it sua sponte. It confirms that a single catastrophic event like a fire can trigger the exception even with multiple defendants and underlying negligent conduct.