Frosini v. Bridgestone Firestone North American Tire, LLC, No. 05-575, 2005 WL 3710393 (C.D. Cal. December 12, 2005).
In somewhat of a role reversal, the plaintiffs in this case filed their complaint in the U. S. District Court for the Central District of California against Bridgestone Corporation and other tire manufacturers, asserting federal jurisdiction under the Class Action Fairness Act of 2005. However, Bridgestone and the other defendants moved for a stay of the action until a California state court could adjudicate the pending action which involved one of the named plaintiffs in the federal suit and Bridgestone. In the state court action, the complaint asserted essentially the same claims against Bridgestone as asserted in the federal action, in which the battlefield had already been bloodied by a removal/remand fight which resulted in the case being remanded back to state court. Further, the plaintiff’s counsel in the state court action (coincidently, the same counsel as in the federal action – surprise, surprise) had already moved to certify the class in the state court, but class certification was denied. (The denial of class certification was on appeal to the California Court of Appeals at the time the federal court drafted its opinion.)
To satisfy the high precedential bar for staying a federal action on the basis of a concurrent state proceeding, Bridgestone attempted to demonstrate the “exceptional circumstances” required to stay the federal action, arguing that the actions addressed the same issues and the subject matter, claims, asked for identical relief, and beyond the jurisdictional requirements, the two suits were virtually identical. The defendants also argued that staying the federal action would avoid piecemeal litigation, and avoid the risk of conflicting results based solely on jurisdiction.
The plaintiffs responded that, to the contrary, this action was “just the type of class action that Congress had in mind when drafting the Class Action Fairness Act . . . and that to stay the proceedings would serve to undermine this congressional intent.” Apparently anticipating, if not conceding, a loss on appeal of the state class certification, the plaintiffs also argued that the federal action would not result in piecemeal litigation, since the state court action only concerned the underlying claims of the two named plaintiffs, not the entire class. Finally, the plaintiffs contended that the state action was an inadequate forum to protect the federal litigants’ rights.
While not explicitly addressing either side’s arguments, Federal District Judge Christina A. Snyder apparently decided that the defendants’ arguments were sufficient, as she concluded that Bridgestone had satisfied its heightened burden, and stayed the federal action for ninety days.