In re Tyco (individual cases)

2004 DNH 094
CourtDistrict Court, D. New Hampshire
DecidedJune 21, 2004
DocketCV-02-1335-B
StatusPublished

This text of 2004 DNH 094 (In re Tyco (individual cases)) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Tyco (individual cases), 2004 DNH 094 (D.N.H. 2004).

Opinion

In re Tyco (individual cases) CV-02-1335-B 06/21/04 P

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

In re Tyco International, Ltd. Multidistrict Litigation (MDL 1335) MDL DOCKET NO. 02-1335-PB Case N o . 03-1336-PB 03-1338-PB 03-1344-PB 03-1345-PB 03-1346-PB 03-1347-PB 03-1349-PB Opinion No. 2004 DNH 094 P

MEMORANDUM AND ORDER

The plaintiffs in seven of the 47 cases that have been

consolidated for pretrial proceedings in this multidistrict

litigation matter have moved to remand their cases to the state

courts in which they were originally filed. The cases are based

exclusively on the Securities Act of 1933 (“the Securities Act”),

15 U.S.C. § 77a-77aa, which until 1998 did not permit the removal

of any case that was deemed to arise under the Securities Act.

Congress created a limited exception to the nonremoval rule when

it adopted the Securities Litigation Uniform Standards Act of 1998 (“SLUSA”), Pub. L . N o . 105-353, 112 Stat. 3227 (codified as

amended at 15 U.S.C. §§ 77p, 77v, 77z-1, 78u-4 and 78bb (1998)).

The question that I must resolve is whether the cases at issue

qualify for removal under SLUSA.1

1 The few courts that have considered whether SLUSA permits the removal of cases based exclusively on the Securities Act are split. In re King Pharmaceuticals, Inc., N o . 2:03-CV-77, slip o p . (E.D. Tenn. Feb. 6, 2004) (citing to legislative history and common sense to hold that cases based on the Securities Act are removable under SLUSA); Kulinski v . Am. Electric Power Co., N o . 02-03-412, slip o p . (S.D. Ohio 2004) (holding cases based on the Securities Act removable because of the exception to the prohibition on removal in § 77v, as amended by SLUSA); Alkow v . TXU Corp., Nos. 3:02-CV-2738-K, 3:02-CV-2739-K, 2003 WL 21056750 (N.D. Tex. May 8 , 2003) (finding SLUSA was passed to counteract a shift in cases to state court and therefore allows the removal of cases based solely on the Securities A c t ) ; Brody v . Homestore, Inc., 240 F. Supp. 2d 1122 (C.D. Cal. 2003) (holding “SLUSA authorizes removal of class actions asserting violations of the 1933 Act” and that this reading is required to not “render the amendment to § 77v(a) meaningless”); but see Williams v . AFC Enters., Inc., N o . 1:03-CV-2490-TWT, slip o p . (N.D. G a . Nov. 2 0 , 2003) (following Eleventh Circuit dicta that SLUSA applies to claims based on state law, court held cases based on the Securities Act were not removable); Nauheim v . Interpublic Group of Cos., N o . 02-C-9211, 2003 WL 1888843 (N.D. Ill. April 1 6 , 2003) (finding “the plain language of the Securities Act, as amended by SLUSA, clearly and unambiguously permits the removal of only those covered class action complaints that are based on State statutory or common law” and does not authorize the removal of cases bases on the Securities A c t ) ; In re Waste Mgmt., Inc. Sec. Litig., 194 F. Supp. 2d 590 (S.D. Tex. 2002) (holding SLUSA does not provide removal for cases based on the Securities A c t ) .

-2- I.

Congress passed SLUSA to prevent plaintiffs in certain

securities fraud class action cases from using state laws and

state courts to avoid the rigorous pleading standards, discovery

limitations, and other requirements of the Private Securities

Litigation Reform Act of 1995 (“PSLRA”). See Pub. L . N o . 105-

353, § 2 , 112 Stat. 3227. Congress attacked the problem

primarily by adding preemption and removal provisions to both the

Securities Act and the Exchange Act of 1934, 15 U.S.C. §§ 78a-

78mm (“Exchange Act”).

The Securities Act’s preemption provision is codified at 15

U.S.C. § 77p(b). It states that

No covered class action based upon the statutory or common law of any State or subdivision thereof may be maintained in any State or Federal court by any private party alleging- (1) an untrue statement or omission of a material fact in connection with the purchase or sale of a covered security; or (2) that the defendant used or employed any manipulative or deceptive device or contrivance in connection with the purchase or sale of a covered security.

15 U.S.C. § 77p(b).

-3- The removal provision is codified at 15 U.S.C. § 77p(c). It

states that

Any covered class action brought in any State court involving a covered security, as set forth in subsection ( b ) , shall be removable to the Federal district court for the district in which the action is pending, and shall be subject to subsection ( b ) .

15 U.S.C. § 77p(c).

Until SLUSA became law, no case that was deemed to arise

under the Securities Act was removable to federal court. SLUSA

amended the nonremoval provision, codified at 15 U.S.C. § 77v, to

create an exception for cases that are removable under § 77p(c).

The nonremoval provision (with the new language emphasized)

Except as provided in section 77p(c) of this title, no case arising under this subchapter and brought in any State court of competent jurisdiction shall be removed to any court of the United States.

15 U.S.C. § 77v (emphasis added). 2

2 SLUSA also amended § 77v’s concurrent jurisdiction provision to strip state courts of jurisdiction over certain cases that arise under the Securities Act. The relevant language (with the new language emphasized) states that [t]he district courts of the United States and the United States courts of any Territory shall have jurisdiction of offenses and violations under this subchapter and under the rules and regulations promulgated by the Commission in respect thereto, and, concurrent with State and Territorial courts, except as provided in section 77p of this title with respect to covered class actions, of all suits in equity and

-4- II.

The parties agree that § 77v bars the removal of the cases

at issue unless they qualify for removal under § 77p(c). Section

77p(c), in turn, applies to “[a]ny covered class action brought

in any State court involving a covered security, as set forth in

subsection (b).” Because it is undisputed that the cases at

issue are “covered class actions”3 and involve “covered

securities,”4 their removability depends upon the meaning of the

phrase “as set forth in subsection (b).”

Plaintiffs argue that “as set forth in subsection (b)”

modifies the term “covered class action.” Because § 77p(b)

applies only to covered class actions that are “based upon the

statutory or common law of any State or subdivision thereof,”

plaintiffs argue that cases such as the ones that are now before

m e , which are based exclusively on the Securities Act, are not

removable under § 77p(c).

actions at law brought to enforce any liability or duty created by this subchapter.

15 U.S.C.

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Related

United States v. Hernandez-Wilson
186 F.3d 1 (First Circuit, 1999)
Novick v. Myers
986 P.2d 1 (Oregon Supreme Court, 1999)
Brody v. Homestore, Inc.
240 F. Supp. 2d 1122 (C.D. California, 2003)
In Re Tyco International, Ltd.
322 F. Supp. 2d 116 (D. New Hampshire, 2004)
In Re Waste Management, Inc. Securities Litigation
194 F. Supp. 2d 590 (S.D. Texas, 2002)

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