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Civil Procedure — class actions

United States Court of Appeals For the Seventh Circuit


Civil Procedure — class actions

Where a lawsuit is, in substance, a class action, it was properly removed to federal court under CAFA.

“[T]he terms of the class settlement approved in state court make clear that Addison has standing to pursue relief from Hartford only in its capacity as class representative. Unlike the district court, we reach the question of standing because it goes directly to the characterization of Addison’s claim as a class action, a threshold inquiry for deciding federal jurisdiction under CAFA. See generally United States v. Ruiz, 536 U.S. 622, 628 (2002) (‘it is familiar law that a federal court always has jurisdiction to determine its own jurisdiction.’). Despite Addison’s artful pleading, its complaint seeks a ruling on Hartford’s duties to Domino on a claim that Domino assigned ‘to the Class (as represented by Plaintiff and its attorneys).’ Such a ruling will determine Hartford’s liability not just to Addison but for the entire $18 million judgment that the state court entered ‘in favor of the Class.’ Moreover, only Addison has standing to pursue this relief on behalf of the class certified by the state court. If any other members of the class sought similar relief from Hartford, they would encounter an insurmountable roadblock. The settlement gave other class members no right to pursue such relief on their own because it assigned Domino’s claims against its insurers only to ‘the Class (as represented by [Addison] and its attorneys).’”

Reversed and Remanded.

13-2729 Addison Automatics, Inc., v. Hartford Casualty Ins. Co.

Appeal from the United States District Court for the Northern District of Illinois, Lee, J., Hamilton, J.

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