Mississippi Ex Rel. Hood v. AU Optronics Corp.

571 U.S. 161, 24 Fla. L. Weekly Fed. S 513, 187 L. Ed. 2d 654, 134 S. Ct. 736, 82 U.S.L.W. 4056, 2014 U.S. LEXIS 645, 2014 WL 113485
CourtSupreme Court of the United States
DecidedJanuary 14, 2014
Docket12–1036.
StatusPublished
Cited by243 cases

This text of 571 U.S. 161 (Mississippi Ex Rel. Hood v. AU Optronics Corp.) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mississippi Ex Rel. Hood v. AU Optronics Corp., 571 U.S. 161, 24 Fla. L. Weekly Fed. S 513, 187 L. Ed. 2d 654, 134 S. Ct. 736, 82 U.S.L.W. 4056, 2014 U.S. LEXIS 645, 2014 WL 113485 (2014).

Opinion

Justice SOTOMAYOR delivered the opinion of the Court.

*164 Under the Class Action Fairness Act of 2005 (CAFA or Act), defendants in civil suits may remove "mass actions" from state to federal court. CAFA defines a "mass action" as "any civil action ... in which monetary relief claims of 100 or more persons are proposed to be tried jointly on the ground that the plaintiffs' claims involve common questions of law or fact." 28 U.S.C. § 1332 (d)(11)(B)(i). The question presented is whether a suit filed by a State as the sole plaintiff constitutes a "mass action" under CAFA where it includes a claim for restitution based on injuries suffered by the State's citizens. We hold that it does not. According to CAFA's plain text, a "mass action" must involve monetary claims brought by 100 or more persons who propose to try those claims jointly as named plaintiffs. Because the State of Mississippi is the only named plaintiff in the instant action, the case must be remanded to state court.

I

*165 A

Congress enacted CAFA in order to "amend the procedures that apply to consideration of interstate class actions." 119 Stat. 4 . In doing so, Congress recognized that "[c]lass action lawsuits are an important and valuable part of the legal system." CAFA § 2. It was concerned, however, that certain requirements of federal diversity jurisdiction, 28 U.S.C. § 1332 , had functioned to "kee[p] cases of national importance" in state courts rather than federal courts. CAFA § 2.

CAFA accordingly loosened the requirements for diversity jurisdiction for two types of cases-"class actions" and "mass actions." The Act defines "class action" to mean "any civil action filed under *740 rule 23 of the Federal Rules of Civil Procedure or similar State statute or rule of judicial procedure." 28 U.S.C. § 1332 (d)(1)(B). And it defines "mass action" to mean "any civil action ... in which monetary relief claims of 100 or more persons are proposed to be tried jointly on the ground that the plaintiffs' claims involve common questions of law or fact." § 1332(d)(11)(B)(i).

For class and mass actions, CAFA expanded diversity jurisdiction in two key ways. First, it replaced the ordinary requirement of complete diversity of citizenship among all plaintiffs and defendants, see State Farm Fire & Casualty Co. v. Tashire, 386 U.S. 523 , 530-531, 87 S.Ct. 1199 , 18 L.Ed.2d 270 (1967), with a requirement of minimal diversity. Under that requirement, a federal court may exercise jurisdiction over a class action if "any member of a class of plaintiffs is a citizen of a State different from any defendant." § 1332(d)(2)(A). The same rule applies to mass actions. See § 1332(d)(11)(A) ("[A] mass action shall be deemed ... removable under [ §§ 1332(d)(2) through (d)(10) ]"). Second, whereas § 1332(a) ordinarily requires each plaintiff's claim to exceed the sum or value of $75,000, see *166 Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 , 554-555, 125 S.Ct. 2611 , 162 L.Ed.2d 502 (2005), CAFA grants federal jurisdiction over class and mass actions in which the aggregate amount in controversy exceeds $5 million. §§ 1332(d)(2), (d)(6), (d)(11)(A). Class and mass actions filed in state court that satisfy CAFA's requirements may be removed to federal court, 28 U.S.C. § 1453 , but federal jurisdiction in a mass action, unlike a class action, "shall exist only over those plaintiffs" whose claims individually satisfy the $75,000 amount in controversy requirement, § 1332(d)(11)(B)(i). 1

B

Respondents manufacture liquid crystal displays, or LCDs. In March 2011, the State of Mississippi sued them in state court, alleging that they had formed an international cartel to restrict competition and raise prices in the LCD market. The State claimed that these actions violated two Mississippi statutes: the Mississippi Antitrust Act, Miss.Code Ann. § 75-21-1 et seq . (2009), and the Mississippi Consumer Protection Act, § 75-24-1 et seq. (2009 and Cum. Supp. 2013). The State sought injunctive relief and civil penalties under both statutes, along with punitive damages, costs, and attorney's fees. It also sought restitution for its own purchases "of LCD products and the purchases of its citizens." App. to Brief in Opposition 65a; § 75-24-11.

Respondents filed a notice to remove the case from state to federal court, arguing that the case was removable under CAFA as either a "class action" or a "mass action." The District Court ruled that the suit did not qualify as a "class action" because it was "not brought pursuant to Federal Rule of Civil Procedure 23 or a 'similar State statute or rule of judicial procedure.' " 876 F.Supp.2d 758 , 769 (S.D.Miss.2012). But it held that the suit did qualify as a "mass action,"

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571 U.S. 161, 24 Fla. L. Weekly Fed. S 513, 187 L. Ed. 2d 654, 134 S. Ct. 736, 82 U.S.L.W. 4056, 2014 U.S. LEXIS 645, 2014 WL 113485, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mississippi-ex-rel-hood-v-au-optronics-corp-scotus-2014.