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Gotham Investors, Et Al. V. Safeco Corporation, Et Al. 08-CV-00940

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Gotham Investors, Et Al. V. Safeco Corporation, Et Al. 08-CV-00940 2 FiLEV . 08-CV-00940-NTC AODGED ENTERED 3 _^ C 1VfD 4 5 UN :.. f. 2006 6 c]ARKus o^ ^qjYc 7 STERN D SrRJCT OF WASHIN'TO . 8 DEFPur, 9 I0 11 12 13 UNITED STATES DISTRICT COURT 14 WESTERN DISTRICT OF WASHINGTON 15 AT SEATTLE 16 17 18 GOTHAM INVESTORS, on behalf of itself and >o CQ8-0940 15+' 19 all others similarly situated, 20 NOTICE OF REMOVAL 21 Plaintiff, 22 231 V. 24 25 PAULA ROSPUT REYNOLDS, JOSEPH W. 26 BROWN, ROBERT S. CLINE, PETER L.S. 27 CURRIE, JOSHUA GREEN III, JOHN S. 28 HAMLIN, KERRY KILLINGER, GARY 29 LOCKE, GERARDO 1. LOPEZ, WILLIAM G. 30 REED, CHARLES R. RINEHART. JUDITH M_ 31 RUNSTAD, SAFECO CORPORATION, and 1 32 LIBERTY MUTUAL INSURANCE v 33 COMPANY, 34 35 Defendants. 36 37 38 a9 TO, The Clerk, United States District Court U`5 40 for the Western District of Washington at Seattle 41 42 A. Removal of State Court Action 43 44 Defendants Paula Rosput Reynolds, Joseph W. Brown, Robert S. Cline, Peter L_S. Currie, 45 46 Joshua Green Ill, John S. Harnlin, Kerry Killinger, Gary Locke, Gerardo 1. Lopez, William G. 47 48 Reed. Charles R. Rinehart , Judith M. Runstad (collectively, the "Director Defendants "), Safeco 49 50 Corporation ("Safeco") and Liberty Mutual Insurance Company ("Liberty Mutual ") are all of the 51 Perkins Coie LL NOTICE OF REMOVAL - 1' 1201 Third Avenue, Suite 4800 Case No. C08- Seattle, WA 98101-3099 Phone: 206.359.8000 ORIGINAL Fax: 206.359.9000 6351]-]006/LEGAL14177038 1 defendants in the above-entitled civil action, which was commenced on or about June 2, 2008, and is still pending in the Superior Court of the State of Washington for King County (the "Superior Court"), as Cause No. 08-2-1 868 1-4 SEA. Through this Notice, defendants pray that this action be removed to this Court from the Superior Court. B. Bases for Jurisdiction in Federal Court Jurisdiction in this Court is premised on both federal question jurisdiction and jurisdiction as provided by the Class Action Fairness Act of 2005 ("CAFA"). 1. Federal Question Jurisdiction The Complaint alleges that Safeco and the Director Defendants breached fiduciary duties and duties of disclosure that they owed to Safeco's shareholders in connection with (1) the proposed merger of Safeco into Liberty Mutual , (2) the concomitant purchase by Liberty Mutual of all outstanding stock owned by Safeco's shareholders , and (3 ) the proxy materials to be provided to Safeco ' s shareholders pursuant to Section 14(a) of the Securities Exchange Act of 1934 ("Exchange Act")_ Although plaintiff purports to assert only claims under state law, the reality is very different. As a publicly traded corporation registered with the SEC, Safeco's duty of disclosure, and that of its directors, cannot be determined without reference to federal securities laws and regulations. Consequently, pursuant to the Artful Pleading Doctrine, plaintiffs claims should be deemed claims arising under federal law over which this Court has original jurisdiction. The Artful Pleading Doctrine holds that, although a plaintiff generally is the master of his or her complaint, the plaintiff nevertheless "may not avoid federal jurisdiction by omitting from ' The Preliminary Proxy Statement was filed with the Securities and Exchange Commission (" SEC") on or about May 23, 2008. Perkins Colt LIP NOTICE OF REMOVAL - 2 1201 Third Avenue, Suite 4800 Case No. C08 - Seattle, WA 98101-3099 Phone : 206359.8000 Fax: 206 . 359.9000 6351 1-1 OO6/LEGA1.14377038. ] the complaint allegations of federal law that are essential to the establishment of his claim." Lippittv. Raymond James Financial Services, Inc. , 340 Fad 1033, 1041 (9th Cir. 2003) (internal quotation marks and citation omitted). Among the situations in which it is appropriate to invoke the Artful Pleading Doctrine to support removal and establish federal jurisdiction are cases, like this one, in which plaintiffs state-law claims implicate a substantial federal question. Id. at 1042. A state-law claim implicates a substantial federal question when (1) a substantial, disputed question of federal law is a necessary element of the well-pleaded state claim, or the claim is an inherently federal claim articulated in state-law terms; or (2) the right to relief depends on the resolution of a substantial, disputed federal question. Id. (internal quotation marks, citations and emphasis deleted). Here, it is not possible to resolve plaintiffs claims without first making determinations concerning disputed issues of federal law. Specifically, the Court will have to make determinations concerning the scope and extent of disclosures that the federal securities laws require Safeco and the Director Defendants to make in the proxy context. See, e.g., 15 U.S.C. § 78n(a); 17 C.F.R. §§ 240.14a-I through 240.14a-101. Furthermore, because plaintiff alleges that "defendants [acted] to conceal material information from plaintiff and Safeco's other public shareholders," Complaint ^ 1; the anti-fraud provisions of the Exchange Act are also implicated. 15 U.S.C. §§ 78j(b), 78n(e); see also 17 C.F.R' §§ 240.10b-5, 240.14a-9. In accord with the Artful Pleading Doctrine. plaintiffs claims arise under the laws of the United States and this Court has original subject-matter jurisdiction under 28 U.S.C. § 1331. 2. CAFA Jurisdiction This Court also has subject-matter jurisdiction based on CAFA. CAFA applies to class action lawsuits. such as this one, where the aggregate number of persons in all proposed plaintiff classes is 100 or more and where the primary defendants are not state officials or entities against whom the Court may be foreclosed from ordering relief- 28 U.S.C. § 1332(d)(5); Serrano v. 180 Connect. Inc. _ 478 F.3d 1018, 1020 (9th Cir. 2007). Perkins Cole Lip NOTICE OF REMOVAL-33 1201 Third Avenue, Suite 4800 Case No. C08- Seattle, WA 98101-3099 Phone: 206.359-8000 Fax: 206. 359.9000 635 t 1- 1006lLEGAL 14377038.1 Assuming these threshold requirements are satisfied , CAFA vests federal courts with original jurisdiction if (1) the aggregate amount in controversy exceeds $5 million and (2) any class member is a citizen of a state different from ay defendant. 28 U.S .C. § I332(d)(2); Serrano, 478 F.3d at 1020-21. Each ofthese requirements is satisfied here: • There can be no serious doubt that the proposed class consists of more than 100 persons. Plaintiff itself alleges that Safeco has over 92 million shares issued and outstanding, and that class members "are so numerous and geographically dispersed, that joinder of all of them would be impracticable." Complaint J 23. • None of the defendants are state governmental entities. • Plaintiff challenges and/or seeks rescissory damages related to a proposed merger that involves the purchase by Liberty Mutual of more than 92 million shares of Safeco stock at a price of $68.25 per share. Even deducting shares held by persons excluded from the class definition, the aggregate amount in controversy far exceeds $5 million. • There is only one named plaintiff (whose state of residence is not identified in the Complaint) and defendants are residents of at least two different states- Washington (Safeco) and Massachusetts (Liberty Mutual). Complaint 1^¶ 6, 19.2 Because plaintiff does not purport to be a corporation, it cannot be a resident of 2 The Complaint does not identify the state of residence of the Director Defendants. In a parallel class action previously filed in this Court, which makes essentially the same allegations as the Complaint in this action, the plaintiff alleged that the Director Defendants are domiciliaries of four different states-Washington, New York, California and Texas. See Complaint 1J¶ 7-19, Loring v. Brown , No. C08-0733 RSM (filed May 9. 2008) ("First Safeco Class Action"). On June 6, 2008, the First Safeco Class Action was reassigned to Judge Zilly and is identified on the Civil Cover Sheet as the related case at Docket No. C08-0733 TSZ. Perkins Coic LLP. NOT-ICE OF REMOVAL - 4 1201 Third Avenue, Suite 4800 Case No. C0- Seattle, WA 98 1 0 1-3 099 Phone: 206.359.8000 Fax: 206.359.9000 63511-1006/LEGAL 14377038.1 both Washington and Massachusetts. Therefore, under CAFA,- this final requirement for jurisdiction is met. Plaintiff nevertheless contends that this action is not removable under CAFA because it "challenges the internal affairs or governance of Safeco." Complaint ¶ 4. In making this contention, plaintiff ignores the language that introduces CAFA's internal affairs or governance exception, and which limits that exception to cases that involve only claims concerning internal affairs or corporate governance issues. In pertinent part, the applicable CAFA provision states: Paragraph (2) shall not apply to any class action that solely involves a claim- (B) that relates to the internal affairs or governance of a corporation or other form of business enterprise and that arises under or by virtue of the laws of the State in which such corporation or business enterprise is incorporated or organized[.] 28 U.S .C. § 1332(d)(9) (emphasis added).3 This action does not solely involve claims that relate to the internal affairs or governance of a corporation . The Complaint contains claims against Liberty Mutual for aiding and abetting breaches of duty allegedly committed by Safeco and the Director Defendants. See Complaint ¶J 42, 50 . The claims against Liberty Mutual do not pertain to the internal affairs or corporate governance of either Safeco or Liberty Mutual. Consequently, the exceptions to federal jurisdiction found in Section 1332(d)( 9) do not apply. Accordingly, pursuant to CAFA, this Court has original jurisdiction over the subject matter of this action under 28 U.S.C.
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