华盛顿诉阿拉巴马州海湾公司等案

In January 2023, Gulfco of Alabama, LLC (doing business as Tower Loan of Hoover) sued Johrnee N. Washington in Jefferson County District Court, Alabama, to recover principal and interest on a loan. Washington answered and filed a "Counterclaim and Class Action" against Gulfco and Tower Loan of Mississippi under the Fair Credit Reporting Act (FCRA). She moved to sever and transfer her claims to the Circuit Court of Jefferson County; the state court granted the motion on September 25, 2024, creating a new civil action. On October 25, 2024, Gulfco removed the case to federal court with Tower Loan's consent. Washington moved to remand, arguing Gulfco waited too long to remove. On June 11, 2025, Judge Madeline Hughes Haikala denied the motion, holding the removal was timely.

The court denied Washington's motion to remand, ruling that the severance order created a new action and triggered the 30-day removal window under § 1446(b)(3). Gulfco removed the action with Tower Loan's consent within that window. The case was therefore properly removed to federal court.

The central dispute was whether Gulfco's removal of the case to federal court was timely under 28 U.S.C. § 1446(b)(3). Washington argued Gulfco waited too long. The court had to determine when the 30-day removal window began—whether from the original filing or from the state court's September 25, 2024 severance order, which created a new action between Washington as plaintiff and Gulfco and Tower Loan as defendants.

The ruling clarified that state court severance orders can create new actions that restart the clock for removal to federal court when federal claims are involved. This affects how consumer credit defendants time their removals in FCRA class actions. The decision also highlights ongoing litigation between consumer borrowers and lending entities over credit reporting practices under FCRA.