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Civil Procedure — class actions — CAFA

By: WISCONSIN LAW JOURNAL STAFF//January 14, 2014//

Civil Procedure — class actions — CAFA

By: WISCONSIN LAW JOURNAL STAFF//January 14, 2014//

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U.S. Supreme Court

Civil

Civil Procedure — class actions — CAFA

Where the only named plaintiff is a state, a class action cannot be brought under CAFA.

Construing “plaintiffs” to include both named and unnamed real parties in interest would stretch the meaning of “plaintiff” beyond recognition. A “plaintiff” is commonly understood to be a party who brings a civil suit in a court of law, not anyone, named or unnamed, whom a suit may benefit. Moreover, respondents’ definition would also have to apply to the mass action provision’s subsequent reference to “plaintiffs” in the phrase “jurisdiction shall exist only over those plaintiffs whose claims [exceed $75,000],” §1332(d)(11)(B)(i). See Brown v. Gardner, 513 U. S. 115, 118. This would result in an administrative nightmare that Congress could not possibly have intended, see Griffin v. Oceanic Contractors, Inc., 458 U. S. 564, 575, where district courts would have to identify hundreds (or in this case, hundreds of thousands) of unnamed parties whose claims are for less than $75,000 and then decide how to dispose of their claims.

701 F. 3d 796, reversed and remanded.

12-1036 Mississippi ex rel. Hood v. AU Optronics Corp.

Sotomayor, J.

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