The plaintiff's act of naming a non-diverse defendant in a state-court lawsuit, against whom the plaintiff has stated no legal claim, and the failure to state a claim is obvious according to the settled rules of the state, to prevent the case from being removed to federal court on diversity grounds (see, for example, Benihana of Tokyo, LLC v. Angelo, Gordon & Co., , at *3 (D. Haw. June 1, 2015)). Alternatively, fraudulent joinder can arise if the plaintiff has stated a claim against a diverse defendant whom the plaintiff fraudulently alleges is non-diverse.