Mississippi, ex rel. Hood v. AU Optronics Corp.

PETITIONER: Mississippi, ex rel. James Hood, Attorney General
RESPONDENT: AU Optronics Corporation, et al.
LOCATION: United States District Court for the Western District of Michigan at Grand Rapids

DOCKET NO.: 12-1036
DECIDED BY: Roberts Court (2010-2016)

CITATION: 571 US (2014)
GRANTED: May 28, 2013
ARGUED: Nov 06, 2013
DECIDED: Jan 14, 2014

Christopher M. Curran - for the respondents
Jonathan S. Massey - for the petitioner

Facts of the case

On March 25, 2011, the State of Mississippi sued a group of liquid crystal display (LCD) manufacturers and claimed that they harmed consumers by engaging in a conspiracy to fix prices for LCD panels, which artificially inflated prices. On June 9, 2011, the respondents jointly removed the case from the Chancery Court of Hinds County to the federal district court and asserted federal jurisdiction was satisfied under the Class Action Fairness Act (CAFA). Class action and mass action suits can be properly removed to federal court under the CAFA.

The State of Mississippi moved to remand the case to state court because the claims in the suit were asserted on behalf of the general public, which prevented the case from falling under federal jurisdiction. The district court granted the motion. The respondents appealed to the United States Court of Appeals of Fifth Circuit, which reversed the lower court's decision. The appellate court held that the suit qualified as a mass action under the CAFA and that Mississippi brought the case in the interest of individual citizens, so the general public exception was not applicable.


Was the case properly removed to federal district court as a mass action under the Class Action Fairness Act (CAFA)?

Media for Mississippi, ex rel. Hood v. AU Optronics Corp.

Audio Transcription for Oral Argument - November 06, 2013 in Mississippi, ex rel. Hood v. AU Optronics Corp.

Audio Transcription for Opinion Announcement - January 14, 2014 in Mississippi, ex rel. Hood v. AU Optronics Corp.

Justice Sotomayor has our opinion this morning in case 12-1036 Mississippi v. AU Optronics Corporation.

The State of Mississippi sued a group of LCD manufacturers alleging that they had engaged in a price fixing scheme in violation of state law.

The manufacturers removed the case to federal court on the theory that on a theory that the sued is a mass action onto the Class Action Fairness Act or the Act.

The act to find mass action to mean any civil action in which monetary relief claims of 100 or more persons are propose to be tried jointly on the ground that the plaintiffs claims involved common questions.

The issue presented is whether Mississippi’s lawsuit is a mass action so define.

The Court of Appeals held that it is reasoning that even though the state is the sole named plaintiff to the suit, the suit -- the states complaint includes a claim for restitution based on LCD purchases made by 100 or more unidentified Mississippi citizens.

In doing so, the Court of Appeals believed that it was required to look pass the number of plaintiffs on the face of the complaint and determine if there are 100 or more unnamed persons who are real parties and interest to the suit.

We reverse.

The Act does not define a mass action to include suits involving monetary claims of 100 or more unnamed real parties and interest.

It instead defines a mass action to include cases involving claims of 100 or more persons that are proposed to be tried jointly on the ground that the plaintiffs' claims involved common questions that, that definition makes clear that the 100 or more persons at issue are the proposed plaintiffs themselves not some unspecified individuals who lack any participation in the suit.

Interpreting the provision to require 100 or more named plaintiffs is consistent with the language used in Rule 20 of the Federal Rules of Civil Procedure, a rule we presume Congress was aware of when it drafted the Act.

Like the mass action provision Rule 20 discusses persons who propose to join in one action as plaintiffs.

Our holding also avoids the many administrative difficulties that would arise if the provision were construed to require identifying every single unnamed individual with an interest in a suit.

And although we have required an inquiry into unnamed real parties at interest and other context, we decline to do so here where the text of the Act commands otherwise.

We therefore hope -- therefore hold that to qualify as a mass action under the plain meaning of the statue, an action must involved monetary claims brought my 100 or more proposed plaintiffs who propose to try their claims jointly in a single trial.

Here there are not 100 name plaintiffs but one, the State of Mississippi.

So the case is not a mass action removable under the Act.

The judgment of the United States Court of Appeals for the Fifth Circuit is accordingly reversed and the cases remanded for further proceedings consistent with this opinion.

The opinion is for unanimous court.

Sarah from Law Aspect

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