Scarinci Hollenbeck, LLC, LLCScarinci Hollenbeck, LLC, LLC

Firm Insights

Supreme Court Issues Key Class-Action Decision

Author: Scarinci Hollenbeck, LLC

Date: April 3, 2013

Key Contacts

Back

The U.S. Supreme Court recently issued a key decision on class-action lawsuits. The case, Standard Fire Insurance Co. v. Knowles, involved the Class Action Fairness Act of 2005 (CAFA), which gives federal district courts original jurisdiction over class actions in which the matter in controversy exceeds $5 million in sum or value.

The law aims to ensure that large class-action lawsuits are decided in federal court and to deter abuse of the class-action process in state courts. To accomplish this goal, when more than $5 million is at stake, the CAFA allows class actions to be removed to federal court, giving defendants the benefit of federal procedural protections.

The Facts of the Case

The question before the Supreme Court was whether a corporate defendant can be forced to litigate in state court if the plaintiff offers a stipulation purporting to waive any recovery above the $5 million threshold on behalf of not only the named plaintiff but any future class members.

In Standard Fire Insurance Co v. Knowles, the complaint was accompanied by an affidavit that included the following language: “I do not now, and will not at any time during this case, whether it be removed, remanded, or otherwise . . . seek damages for the class as alleged in the complaint to which this stipulation is attached in excess of $5,000,000 in the aggregate (inclusive of costs and attorneys’ fees). I understand that this stipulation is binding, and it is my intent to be bound by it.”

The Supreme Court’s Decision

In a unanimous opinion, the justices concluded that the stipulation stating that the class would seek less than five million dollars in damages did not defeat federal jurisdiction under the CAFA.

As explained by the Court in a brief opinion, the precertification stipulation can tie Knowles’ hands because stipulations are binding on the party who makes them. However, it cannot legally bind members of the proposed class before the class is certified. “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,” the Court concluded.

The decision is good news for businesses. Groups, including the U.S. Chamber of Commerce, had argued that allowing damages stipulations to defeat federal jurisdiction would encourage the same forum-shopping that Congress intended to stop by enacting CAFA.

If you have any questions about this case or would like to discuss the legal issues involved, please contact me, Christine Vanek, or the Scarinci Hollenbeck attorney with whom you work. 

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Scarinci Hollenbeck, LLC, LLC

Related Posts

See all
“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy post image

“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy

A “no comment” response is sometimes the right call when a legal problem arises. As a blanket policy, however, it lets allegations go unanswered, deadlines pass, evidence disappear, and manageable disputes grow into expensive litigation. The businesses that fare best are usually the ones that say little publicly while acting decisively behind the scenes. When […]

Author: Sean M. Pena

Link to post with title - "“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy"
Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders post image

Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders

Utility-scale battery energy storage systems (BESS) are becoming an increasingly important component of the electric grid throughout New Jersey, New York, and Pennsylvania. As renewable generation expands, electricity demand increases and grid operators seek greater flexibility, battery storage can help balance supply and demand while providing additional capacity and reliability. For developers, battery storage presents […]

Author: Nicholas Wall

Link to post with title - "Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders"
Navigating Disputes: Hire a Partnership Dispute Lawyer post image

Navigating Disputes: Hire a Partnership Dispute Lawyer

A falling out between partners can be disastrous for any business. In many cases, the partnership will not survive. If you are in an unworkable situation with your partners, it may be time to consult a partnership dispute lawyer experienced in handling partnership breakups and dissolutions before the situation deteriorates any further. It is easy […]

Author: Jay McDaniel

Link to post with title - "Navigating Disputes: Hire a Partnership Dispute Lawyer"
Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know post image

Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know

When a company enters Chapter 11 bankruptcy, many assume the process will culminate in a lengthy reorganization plan. However, distressed businesses are increasingly being sold through a different mechanism — a sale under Section 363 of the United States Bankruptcy Code. A Section 363 sale allows a company, as a debtor-in-possession in bankruptcy, to sell […]

Author: John D. Giampolo

Link to post with title - "Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know"
Zoning Laws Explained: What You Need to Know Before Buying Property post image

Zoning Laws Explained: What You Need to Know Before Buying Property

Before buying property, it is critical to determine whether local zoning laws may affect your plans. If you plan to redevelop the property, you will want to confirm that local zoning regulations permit development as intended. If acquiring property that is already developed, you must verify that the use is permitted in the underlying zoning […]

Author: Wendy Rubinstein Quiroga

Link to post with title - "Zoning Laws Explained: What You Need to Know Before Buying Property"
Special Needs Trusts in New Jersey: Planning for Your Loved One’s Future post image

Special Needs Trusts in New Jersey: Planning for Your Loved One’s Future

For parents of a child with a disability, estate planning raises concerns that go well beyond deciding who will inherit their assets. Parents may spend years making sure their child has the right care, services, and support. Eventually, they must also confront a difficult question: Who will take over when they can no longer do […]

Author: George McGowan

Link to post with title - "Special Needs Trusts in New Jersey: Planning for Your Loved One’s Future"

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Sign up to get the latest from our attorneys!

Explore What Matters Most to You.

Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.

Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.

Let`s get in touch!

* The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Confidential or time-sensitive information should not be sent through this form. By providing a telephone number and submitting this form you are consenting to be contacted by SMS text message. Message & data rates may apply. Message frequency may vary. You can reply STOP to opt-out of further messaging.
“If you would like to submit a file, please email it directly to info@sh-law.com.

Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!