Maya v. Centex Corp.
658 F.3d 1060
| 9th Cir. | 2011Background
- Plaintiffs are individual homeowners who purchased new homes from eight national builders 2004–2006.
- Plaintiffs allege misrepresentations and omissions about neighborhood stability and residents, and about lending practices financing high-risk buyers.
- They seek damages, fees, rescission, and injunction under fraud, negligent misrepresentation, implied covenant, CBPC.
- Plaintiffs contend marketing and financing created artificial demand, inflating prices and causing later foreclosures and blight in their neighborhoods.
- The district court dismissed for lack of Article III standing; the Ninth Circuit reverses, permitting amendment and potentially expert causation proof.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for overpayment and rescission | Maya plaintiffs have injury-in-fact from overpayment and would not have purchased absent disclosure. | Plaintiffs lack concrete ongoing injury and causal link to defendants' conduct. | Injury-in-fact established; remand to allow amendment. |
| Standing for decreased value and desirability | Present decrease in home value and quality of life are cognizable injuries. | Causation to defendants' actions is insufficient on current record. | Cognizable injuries; amendment and expert causation evidence permitted. |
| Judicial handling of standing vs. 12(b)(6) standards | Standing analysis should not be conflated with merits under 12(b)(6). | District court appropriately applied dismissal standards. | District court erred; standing analysis governs subject-matter jurisdiction; remand for amendment. |
Key Cases Cited
- City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (standing requires actual, concrete controversy)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (injury-in-fact must be concrete and particularized)
- Friends of the Earth v. Laidlaw, 528 U.S. 167 (2000) (injury must be actual or imminent and redressable)
- Seldin v. City of Seldin, 422 U.S. 490 (1975) (standing analysis is about jurisdiction, not merits)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; plausibility requirement applies to merits, not standing)
- Twombly v. Bell Atlantic, 550 U.S. 544 (2007) (pleading standard requires plausible claims)
- Gladstone Realtors v. Vill. of Bellwood, 441 U.S. 91 (1979) (present diminution in home value is cognizable injury)
- Barnum Timber Co. v. U.S. EPA, 633 F.3d 894 (9th Cir. 2011) (expert causation evidence may be necessary to prove link to injuries)