We have reported previously on cases in which federal courts had declined CAFA jurisdiction over parens patriae actions brought by state attorneys general.  In Mississippi ex rel. Hood v. AU Optronics Corp., 701 F.3d 796 (5th Cir. 2012) (No. 12-60704), the Fifth Circuit reached a different result, finding that the State of Mississippi’s suit was a mass action, which could be removed to federal court.  Mass actions are statutorily defined as cases seeking monetary relief on behalf of 100 or more persons that are proposed to be tried jointly.  In deciding whether the State of Mississippi’s suit involved the claims of 100 or more persons, the Fifth Circuit relied on its prior decision that instructed the court to “pierce the pleadings and look at the real nature of the State’s claims.”  It found the complaint, the state statute, and the common law all supported the conclusion that the Mississippi Attorney General’s claims were brought on behalf of Mississippi consumers and sought recovery on behalf of more than 100 persons.  The court also addressed the “general public” exception to the mass action rule, which provides a suit is not a mass action if the claims are asserted on behalf of the general public, rather than individual members of a purported class.  Again applying its prior precedent, the court found the claims were brought on behalf of Mississippi citizens, although it recognized this interpretation could render the exception “a dead letter.”