(1) that there is no possibility that plaintiff can establish a cause of action against Robertson, or (2) that “there was outright fraud in the plaintiffs pleading of jurisdictional facts.” See Marshall v. Manville Sales Corp., 6 F.3d 229, 232 (4th Cir.1993) (quoting B., Inc. v. Miller Brewing Co., 663 F.2d 545, 549 (5th Cir.1981)). The burden of demonstrating fraudulent joinder is heavy. Id. The defendants must show that plaintiff cannot establish a claim against the non-diverse defendant even after resolving all issues of fact and law in the plaintiffs favor. Id. at 232-233 (citing Poulos v. Naas Foods, Inc., 959 F.2d 69, 73 (7th Cir.1992)); see also Hartley v. CSX Transp., Inc., 187 F.3d 422, 424 (4th Cir.1999); Carriere v. Sears, Roebuck and Co., 893 F.2d 98, 100 (5th Cir.1990) (<HOLDING>). Moreover, “[a] claim need not ultimately
holding that the evidence is viewed in the light most favorable to the nonmoving party and all doubts are resolved against the moving party holding that disputed questions of fact and all ambiguities in state law must be resolved in favor of the nonmoving party holding that statutes and ordinances are presumed to be constitutional and all reasonable doubts must be resolved in favor of constitutionality holding that any doubt as to the propriety of granting relief must be resolved in favor of the party when the party is not responsible for the error that caused the default judgment holding that a party will be deemed fraudulently joined if after all disputed questions of fact and all ambiguities in the controlling state law are resolved in the plaintiffs favor the plaintiff could not possibly recover against the party whose joinder is questioned