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Civil Procedure — class actions — CAFA; stipulations

U.S. Supreme Court


Civil Procedure — class actions — CAFA; stipulations

A plaintiff in a class action cannot defeat federal jurisdiction by stipulating that damages will not exceed $5 million.

Here, the precertification stipulation can tie Knowles’ hands because stipulations are binding on the party who makes them, see  Christian Legal Soc. Chapter of Univ. of Cal., Hastings College of Law v. Martinez, 561 U. S. ___. However, the stipulation does not speak for those Knowles purports to represent, for a plaintiff who files a proposed class action cannot legally bind members of the proposed class before the class is certified. See Smith v. Bayer Corp., 564 U. S. ___, ___. Because Knowles lacked authority to concede the amount in controversy for absent class members, the District Court wrongly concluded that his stipulation could overcome its finding that the CAFA jurisdictional threshold had been met

Vacated and remanded.

11-1450 Standard Fire Ins. Co. v. Knowles

Breyer, J.

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