Pre-service removal—known colloquially as “snap removal”—continues to be adopted in more jurisdictions. For a basic explanation of snap removal, see Faegre Drinker’s prior posts here.
In Doe v. Daversa Partners, 2021 WL 736734, at *3 (D.D.C. Feb. 25, 2021), the U.S. District Court for the District of Columbia joins the Second, Third, and Fifth Circuit Courts of Appeal affirming the practice of snap removal. Noting that the D.C. Circuit had not yet opined on the issue, the Daversa court provided a thorough analysis and rationale for refusing remand under the circumstances.