A quick word about this case. In Mississippi ex rel. Hood v. AU Optronics Corp., ___ U.S. ___ (1/14/14), the Supreme Court of the United States held that an action by a state, as the sole named plaintiff, to obtain restitution on behalf of itself and its citizens was not a "mass action" for purposes of the Class Action Fairness Act (CAFA).
It will be interesting to see whether this case has any impact on the question of whether a representative action under the 2004 Labor Code Private Attorneys General Act (PAGA) is considered a class action or mass action for CAFA removal purposes.
Mississippi ex rel. Hood v. AU Optronics Corp. is available here.