In Santamaria v. Sears, Roebuck & Co., ___ F.3d ___ (7th Cir. Oct. 19, 2006), the Seventh Circuit (Judge Posner) affirmed an order remanding a pre-CAFA action to California state court, where it was originally filed. The case was MDL'd to the Northern District of Illinois after a federal judge in California denied plaintiffs' motion to remand. On reconsideration, the federal judge in Illinois remanded the case back to California state court, and the defendant appealed to the Seventh Circuit. The Seventh Circuit held that the federal judge in Illinois had the power to reconsider the California judge's ruling, then held that filing an amended complaint adding two new class representatives as plaintiffs did not "kick off a new action" for CAFA purposes. In reaching the latter conclusion, the Court interpreted California law governing whether a later-filed action "relates back" to the original filing date (a rule that comes up mainly in the context of statute of limitations analyses). [Hat tip: How Appealing.]
UPDATE: For more on the Santamaria decision, see this post at Consumer Law and Policy Blog.