Yesterday, the Ninth Circuit issued a new CAFA decision, Abrego v. Dow Chemical Co., ___ F.3d ___ (9th Cir. Apr. 4, 2006). Its key holdings are (1) CAFA did not alter the burden of proving that federal removal jurisdiction is appropriate; the defendant retains that burden (slip op. at 16-23); (2) for a "mass action" to be subject to removal, at least one plaintiff's claims must individually meet the $75,000 jurisdictional requirement (slip op. at 23-32); and (3) the district court has discretion to deny jurisdictional discovery; CAFA does not require that such discovery be permitted (slip op. at 32-38). The decision addresses the "bewildering" (slip op. at 23) language of CAFA in some detail and is worth a read.