McCalley v. Samsung Electronics America, Inc., Civil Action No. 07-2141, 2008 WL 878402 (D.N.J. March 31, 2008).
The TVs were defective, not the plaintiffs. This case holds that CAFA confers federal court jurisdiction over a class action containing claims brought under the Magnuson-Moss Warranty Act (“MMWA”), 15 U.S.C. §§2301-2312, even if the claims do not meet MMWA’s own requirements for federal court jurisdiction.
Under MMWA, a plaintiff may not bring a claim in federal court (a) if the amount in controversy of any individual claim is less than the sum or value of $25; (b) if the amount in controversy is less than the sum or value of $50,000 (exclusive of interests and costs) computed on the basis of all claims to be determined in the suit; or (c) if the action is brought as a class action and the number of named plaintiffs is less than one hundred.” Id. at *4 (citing 15 U.S.C. §§ 2310(d)(3)).
Even though the McCalley class had fewer than one hundred plaintiffs, the United States District Court for the District of New Jersey held that CAFA creates an alternative basis for federal jurisdiction over the MMWA claims.
The court applied the well-known principle of statutory construction that courts are to presume that Congress enacts legislation with knowledge of existing law and, consequently, that newly-enacted statutes are harmonious with the existing law. Id. (citations omitted).
Presuming that Congress must have been aware of MMWA’s limited jurisdictional provisions and intended to expand them with CAFA, and finding that plaintiffs sufficiently alleged CAFA jurisdiction, the court concluded that federal jurisdiction existed based on CAFA even though plaintiffs could not satisfy MMWA’s requirements for federal jurisdiction. Id. at *5. So, if you cannot satisfy MMWA’s requirements for federal jurisdiction, give CAFA a try.
By: Rose Marie L. Fiore