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ARTICLE · 26 MAY 2026

Doctor’s Orders: Michigan Data Breach Class Action Dismissed Due To The CAFA’s Home-State Exception

Duane Morris LLP
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A federal court in Michigan dismissed two data breach class actions after finding that over two-thirds of the proposed class members were Michigan citizens, triggering CAFA's home-state exception.

United StatesLitigation, Mediation & Arbitration
Gerald Maatman, Jr.
Gerald Maatman, Jr.
George J. Schaller
George J. Schaller
Denis Yavorskiy
Denis Yavorskiy
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Duane Morris Takeaways: On May 26, 2026, in Berven v. Sturgis Hosp., Inc., 25-CV-1142 (W.D. Mich. May 26, 2026), Judge Robert J. Jonker of the U.S. District Court for the Western District of Michigan dismissed two related data breach class actions for lack of subject matter jurisdiction, finding that the Class Action Fairness Act’s (“CAFA”) home-state exception prevented the Court from exercising jurisdiction over the cases. 

The Court found that the defendant, Sturgis Hospital, Inc., carried its burden of proving that the CAFA’s home-state exception applied by demonstrating that it is more likely than not that over two-thirds of the class members are Michigan citizens. Sturgis Hospital’s records suggested that roughly 90% of its employees and former patients, the two populations impacted by the alleged data breach, reside in Michigan. Companies facing data breach and other class actions should consider similar ways to challenge jurisdiction by invoking the home-state exception.

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