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Understanding CAFA’s ‘Amount in Controversy’ Requirements

When it comes to medical device and pharmaceutical lawsuits, the class action lawsuit is very common. In a class action lawsuit, one plaintiff or a group of plaintiffs files a lawsuit on behalf of a class of people who have similar legal and factual allegations. In general, there are four requirements that the plaintiffs must satisfy before a court will certify the matter as a class action. First, the class must be so numerous that it is not practical to join all of the prospective plaintiffs in one lawsuit. Next, there must be common questions of fact and law among the class members. Third, the claims or defenses that the representative plaintiffs intend to assert must be typical of the class members. And finally, the representative plaintiffs must advance the class interests fairly and with adequate protection.

There have been many laws and court opinions that define the basic rules and requirements for class action lawsuits. One of them is the federal Class Action Fairness Act (CAFA), which expanded subject matter jurisdiction for federal class action cases. A federal court may assert jurisdiction over a class action lawsuit when the amount in controversy exceeds $5,000,000 and when the class consists of at least 100 members, among other requirements.

In 2015, the Ninth Circuit Court of Appeals decided an important case that had broad implications for class action lawsuits. In that case, the plaintiff was an employee who brought a lawsuit in state court, asserting a number of workplace violations and wage requirement violations. Overall, the plaintiff asserted 10 causes of action, but only nine of them included class claims.

The total amount of damages that the plaintiff requested for the class claims was $1,654,874, while the amount sought for the single non-class claim was $3,247,950. This amounted to roughly $4,900,000 and would exceed $5,000,000 once attorneys’ fees were added. The defendants filed a motion to remove the lawsuit to federal court, based on CAFA. The federal district court rejected the plaintiffs’ request to remand the action to state court, and the plaintiffs appealed.

On review, the court concluded that although the plaintiffs’ claims satisfied the numerosity and diversity requirements under CAFA, they failed to satisfy the amount in controversy requirement, which requires a claim to involve more than $5,000,000 in damages. The court concluded that the non-class claim could not be used to satisfy the amount in controversy requirement under CAFA. This has important implications for plaintiffs who wish to proceed with their lawsuit as a class action.

At Moll Law Group, our experienced team of class action litigators has handled a wide variety of lawsuits across the United States, including in Illinois, Texas, New York, and Florida. From dangerous medical devices to toxic exposure to product liability, our litigators understand how to navigate the class action lawsuit system and understand how challenging this process can be for victims and their families. We offer a free consultation to help you learn about your potential lawsuit and how we may be able to assist you with obtaining compensation. To get started, call us now at 312-462-1700 or contact us online.

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