Chambers v. Stihl Incorporated USA, 4:22-cv-00688

Plaintiff (Chambers) sued Stihl in Arkansas state court alleging only violations of the Magnuson-Moss Warranty Act (MMWA) based on warranties that allegedly bar third‑party repairs/parts.
Stihl removed the case to federal court under CAFA (28 U.S.C. § 1332(d)), asserting diversity class-action jurisdiction.
Plaintiff moved to remand, arguing the MMWA’s own federal‑court jurisdictional prerequisites apply (individual claim minimums and a 100‑named‑plaintiff rule) and that CAFA cannot override them.
Alternatively, Plaintiff argued Stihl failed to carry the burden of showing the CAFA $5,000,000 amount‑in‑controversy threshold was met.
Stihl submitted declarations and calculations (including potential injunctive relief, declaratory relief, and attorneys’ fees) to show the aggregate controversy plausibly exceeds $5,000,000.
The court denied remand: it concluded CAFA jurisdiction can govern and found Stihl met the preponderance‑of‑the‑evidence showing that the amount‑in‑controversy exceeds $5,000,000; Plaintiff failed to prove to a legal certainty the case falls below that threshold.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MMWA’s own jurisdictional thresholds bar federal jurisdiction absent meeting them	MMWA’s subsection (d)(3) controls; CAFA cannot supplant MMWA’s stricter thresholds	CAFA provides an alternate basis for federal jurisdiction; once CAFA thresholds are met, MMWA’s additional thresholds need not be satisfied	Court held CAFA can supply jurisdiction; MMWA thresholds need not be independently met when CAFA applies
Whether the CAFA $5,000,000 amount‑in‑controversy is satisfied	Stihl did not prove the controversy exceeds $5,000,000	Stihl’s declarations and valuation of requested injunctive/declaratory relief plus attorneys’ fees plausibly and preponderantly show > $5,000,000	Court held Stihl met its preponderance burden; Plaintiff failed to show to a legal certainty the amount is below $5,000,000

Rowland v. Bissell Homecare, Inc., 73 F.4th 177 (3d Cir.) (argues MMWA’s jurisdictional rules conflict with CAFA)
Floyd v. Am. Honda Motor Co., 966 F.3d 1027 (9th Cir.) (holds CAFA should not override MMWA absent clear intent)
Leflar v. Target Corp., 57 F.4th 600 (8th Cir.) (assumes without deciding CAFA can suffice such that MMWA thresholds need not be independently met)
Lizama v. Victoria’s Secret Stores, LLC, 36 F.4th 762 (8th Cir.) (describes burdens for establishing amount‑in‑controversy)
Westerfield v. Independent Processing, LLC, 621 F.3d 819 (8th Cir.) (summarizes CAFA jurisdictional requirements)
Dack v. Volkswagen Grp. of Am., 565 F. Supp. 3d 1135 (W.D. Mo.) (applies CAFA over MMWA thresholds)