News & Analysis as of

Removal Class Action

Bradley Arant Boult Cummings LLP

Amending Away Federal Jurisdiction: Supreme Court Holds That Federal Jurisdiction Can Be Divested by Amendment

Federal courts can adjudicate state-law claims arising out of the same facts as federal-law claims under 28 U.S.C. § 1367, but what happens if, after removal, the plaintiff amends her complaint to remove the federal questions...more

Carr Maloney P.C.

Supreme Court Announces Bright Line Rule in Determining Federal Courts’ Subject-Matter Jurisdiction

Carr Maloney P.C. on

On January 15, 2025, the Supreme Court of the United States in Royal Canin U.S.A., Inc., et al. v. Wullschleger et al., upheld the Eighth Circuit’s decision, holding that when a plaintiff amends their complaint and deletes...more

Carlton Fields

Royal Canin v. Wullschleger: A Primer on Jurisdiction

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In the Supreme Court’s latest opinion, Royal Canin U.S.A. Inc. v. Wullschleger, the court takes us back to basics on the basis for federal question and supplemental jurisdiction....more

Robinson Bradshaw

A Pet Lovers’ Quarrel in the U.S. Supreme Court Could Determine Whether Class Actions Can Be Remanded to State Court

Robinson Bradshaw on

Two Missouri pets—and what’s in their prescription food—may ultimately determine where and how class actions are litigated. Earlier this month, the U.S. Supreme Court held oral argument in Royal Canin U.S.A., Inc. v....more

McGuireWoods LLP

Eighth Circuit Confirms That No Anti-Removal Presumption Applies under CAFA

McGuireWoods LLP on

The Eighth Circuit recently held that a district court “applied the wrong legal standard” when it remanded a case after removal under the Class Action Fairness Act (“CAFA”). In Leflar v. Target Corp., the district court held...more

Jenner & Block

Seventh Circuit Offers Useful Reminders about Removal

Jenner & Block on

In Railey v. Sunset Food Mart, Inc., -- F.4th --, No. 21-2533, 2021 WL 4808222 (7th Cir. Oct. 15, 2021), the U.S. Court of Appeals for the Seventh Circuit affirmed the district court’s order remanding a class action asserting...more

Carlton Fields

CF on Cyber: An Update on the Florida Security of Communications Act (FSCA)

Carlton Fields on

Since the beginning of 2021, more than two dozen class action cases have been filed in Florida state court under Florida's Security of Communications Act. The act has, in some form, been on the books for more than 50 years....more

BakerHostetler

Ninth Circuit Again Complicates CAFA Removal Standards

BakerHostetler on

Congress enacted the Class Action Fairness Act to address perceived problems with the handling of class actions by courts. Among its provisions was one permitting removal of more class action claims to federal court. ...more

Kilpatrick

Ninth Circuit: two pro-defendant decisions clarify burdens regarding CAFA’s $5 million jurisdictional threshold

Kilpatrick on

Takeaway: Class defendants prefer federal court. In any putative class action filed in state court, the first issue to analyze is whether the case can be removed to federal court, and any such analysis typically involves...more

Proskauer - California Employment Law

Class Action Was Improperly Removed To Federal Court Under CAFA

Adams v. West Marine Prods., Inc., 958 F.3d 1216 (9th Cir. 2020) - Adrianne Adams filed a putative wage and hour class action in state court, which her former employer (West Marine) removed to federal court under the...more

McGlinchey Stafford

Florida Real Property & Business Litigation Report, Volume 13, Issue 26

McGlinchey Stafford on

Liu v. Securities And Exchange Commission, Case No. 18–1501 (2020). Equitable relief, including disgorgement, is permissible under the Securities Act of 1933, 15 U. S. C. §77a et seq., so long as it does not exceed a...more

Robinson+Cole Class Actions Insider

Tendering Full Relief to Moot a Class Action: It’s Still Possible in Illinois

When a business is sued in a proposed class action and there is only a small amount at stake on the named plaintiff’s claim, often one of the first thoughts that comes to mind is: can’t we just pay the full value of the named...more

Skadden, Arps, Slate, Meagher & Flom LLP

Securities Class Action Filings Continue Record Pace

Several securities litigation trends over recent years show no signs of abating in 2020. Federal securities class action filings seem likely to remain at elevated levels. Last year, for the third consecutive year, more than...more

Carlton Fields

Eleventh Circuit Takes Life Insurance Reinstatement Claims at Face Value for CAFA Amount-In-Controversy Purposes

Carlton Fields on

The Eleventh Circuit recently examined the application of the $5 million amount-in-controversy requirement under the Class Action Fairness Act (CAFA) to disputes over life insurance premiums and policies. It concluded that...more

Kilpatrick

Ninth Circuit makes multiple pro removal rulings in reversing sua sponte CAFA remand

Kilpatrick on

Virtually every defendant facing a state court class action will examine its potential removability under the Class Action Fairness Act (“CAFA”). Indeed, CAFA’s entire point was to move large class actions to federal court. ...more

Carlton Fields

A Dart Across the Bow

Carlton Fields on

The Ninth Circuit Court of Appeals recently underscored that removal practice under the Class Action Fairness Act (CAFA) differs in some important respects from traditional removal practice in non-CAFA cases. It did so...more

Mitchell, Williams, Selig, Gates & Woodyard,...

How Much is Enough to Remove? Considerations that Shouldn't be "Smuggled into the Judicial Inquiry."

A plaintiff filed a class-action complaint in state court alleging a potential liability of $2.9 million to the class, plus fees and punitive damages. The defendant conducted its own calculation and determined that the amount...more

Moore & Van Allen PLLC

U.S. Supreme Court Limited Authority to Remove Class Actions to Original Defendants, Third-Party Counterclaim Defendants May Not...

Moore & Van Allen PLLC on

A defendant by any other name does not smell as sweet when it comes to removing class actions from state court to federal court, even under the Class Action Fairness Act of 2005 (“CAFA”). Congress passed CAFA to address...more

King & Spalding

Supreme Court Limits Removal Authority of Counterclaim Defendants

King & Spalding on

On May 28, 2019, a divided Supreme Court held in a 5–4 opinion that third-party counterclaim defendants cannot remove putative class actions to federal court under the general federal removal statute, 28 U.S.C. § 1441, or the...more

K&L Gates LLP

“Any Defendant” Does Not Really Mean “Any Defendant”

K&L Gates LLP on

The U.S. Supreme Court Limits Parties Entitled to Seek Removal of Class Action Claims Under CAFA - In a recent decision addressing federal court jurisdiction, the U.S. Supreme Court held that third-party counterclaim...more

Moore & Van Allen PLLC

U.S. Supreme Court Said “No” to Class Arbitration in Employment-Related Data Breach Dispute Because Arbitration Agreement...

Moore & Van Allen PLLC on

The U.S. Supreme Court issued two 5-4 decisions in as many months regarding class procedures. Lamp Plus, Inc. v. Varela, 587 U. S. ____ (2019) was favorable to corporate defendants by limiting the availability of class...more

Foley & Lardner LLP

Facing a Class Action Complaint as a Third-Party Defendant? Time to Get Comfortable in State Court

Foley & Lardner LLP on

From the class action defense perspective, companies and counsel alike are almost always looking for an angle to move a state-filed putative class action to the more rigorous environment of the federal courts.  Congress...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Supreme Court Rules on Class Action Removal Limits for Third-Party Counterclaim Defendants

In Home Depot U. S. A., Inc. v. Jackson, No. 17-1471 (May 28, 2019), the Supreme Court of the United States addressed whether third-party counterclaim defendants in class actions have authority under the general removal...more

BakerHostetler

When a Third-Party Defendant is Not a Defendant – Supreme Court Reinforces Removal Loophole

BakerHostetler on

In a 5-4 decision written by Justice Clarence Thomas, and in which Justices Ginsburg, Breyer, Sotomayor and Kagan joined, the U.S. Supreme Court recently held that third-party defendants in state court actions cannot remove...more

Bradley Arant Boult Cummings LLP

“Any” Doesn’t Mean “All”: In Home Depot, SCOTUS Says “Any Defendant” Doesn’t Include Third-party Defendants Facing Class Claims

To the surprise of many observers (including us), the Supreme Court held last week in Home Depot USA Inc. v. George Jackson that a third-party defendant could not remove class action claims – under either the general removal...more

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