In United Steel Workers v. Shell Oil Co., the Ninth Circuit recently held that, in cases with multiple defendants, CAFA entitles one defendant to remove an entire action. After United Steel Workers filed a class action in California state court against Shell Oil Company and Tesoro Refining and Marketing Company, each defendant filed its own notice of removal. Shell Oil’s notice was filed first, but both notices asserted federal question and CAFA jurisdiction. The district court remanded the case to state court, however, and ruled that both notices were defective because neither included the consent of the other defendant. The Ninth Circuit reversed the remand, asserting that while the judge-created rule of unanimity has “traditionally required that all defendants consent to, or join in, removal,” CAFA overrides this requirement. According to the court, “Because the case is governed by CAFA and the rule of unanimity is inapplicable, Shell removed the action as a whole, including claims against Tesoro.” The court noted that Tesoro could not have prevented Shell’s removal even if it wished to do so, let alone by filing a separate notice of removal. The Ninth Circuit joins the Eleventh Circuit in holding that CAFA removal does not require the consent of all defendants.