(U.S. 4th Cir., Civil Procedure, Contracts, Government Law, Labor & Employment Law) In plaintiffs' action against defendants-labor unions, alleging that the union provided them with false information regarding their eligibility to receive retirement incentive packages in 2007, judgment of the district court is affirmed in part, vacated and reversed in part and remanded where: 1) the court of appeals adopts the last-served defendant rule as the law of this circuit, and thus, the district court correctly ruled that defendants timely filed the joint notice of removal; but 2) the district court was without subject matter jurisdiction over the retirees' claims because the doctrine of complete preemption does not apply here to create a basis for removal under 28 U.S.C. section 1441.

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