Seventh Circuit -- Brian Cleary v. Philip Morris Incorp

Violation of consumers' right to know about risks cannot independently support an unjust enrichment claim -- many members of class would not have suffered injury.

Post-removal destruction of diversity does not mandate remand under CAFA.

Expansion of the claim to other manufacturers' "Lights" brands properly barred, as different transaction/occurrence, insufficient notice to existing defts.

No ruling whether unjust enrichment can survive as an independent c/a under Illinois law.

Brian Cleary v. Philip Morris Incorp.