Melvin Wallace v. ConAgra Foods, Inc.
2014 U.S. App. LEXIS 6230
8th Cir.2014Background
- Consumers allege certain Hebrew National kosher products are not 100% kosher and seek class certification for all U.S. buyers over several years.
- ConAgra Foods, Inc. removed the case from Minnesota state court to federal court under CAFA and moved to dismiss for lack of standing and jurisdiction.
- District court dismissed with prejudice, basing the ruling on First Amendment concerns about adjudicating religious questions.
- Court vacates the district court’s judgment and remands to state court due to lack of Article III standing and CAFA jurisdiction.
- Opinion addresses whether CAFA extends federal jurisdiction to cases with only statutory injuries and whether remand or dismissal without prejudice is proper when jurisdiction is lacking.
- This appeal focuses on standing, not on the merits of the state-law claims or the truth of the labeling allegations.
- Note: The court ultimately remands the case to Minnesota state court for lack of federal jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the consumers have Article III standing to sue | Consumers allege concrete economic injury from overpaying for supposedly kosher product | Consumers cannot prove particularized, actual injury to their own purchases | No standing; lack of concrete, particularized injury to specific purchases |
| Whether CAFA extends federal jurisdiction to claims with injury-in-law but no injury-in-fact | CAFA broadens jurisdiction for interstate cases based on statutory violations | CAFA cannot bypass injury-in-fact requirement; Congress did not intend to erase Article III limits | CAFA does not extend federal jurisdiction for bare statutory violations without injury-in-fact |
| Remedy when federal jurisdiction is lacking | Court should retain case in federal court for removal-related issues | Dismissal with prejudice was improper; remand is proper | Remand to state court required; dismissal with prejudice reversed |
| Whether the First Amendment issue should have been decided by the district court | Question of religious liberty under First Amendment controls jurisdictional analysis | First Amendment concerns do not authorize federal jurisdiction over state-law claims absent standing | Court did not decide a First Amendment issue; jurisdictional questions control |
Key Cases Cited
- Ashwander v. TVA, 297 U.S. 288 (1936) (avoid deciding constitutional questions if unnecessary)
- Burton v. United States, 196 U.S. 283 (1905) (do not decide constitutional questions unless necessary)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (injury in fact required; standing constrained by personal impact)
- Summers v. Earth Island Inst., 555 U.S. 488 (2009) (injury in fact hard floor cannot be removed by statute)
- In re Bridgestone/Firestone, Inc., 288 F.3d 1012 (7th Cir. 2002) (describes injury-in-fact requirements for product cases)
- Clapper v. Amnesty Int’l USA, 133 S. Ct. 1138 (2013) (speculation cannot satisfy injury-in-fact; standing must be concrete)
- Zurn Pex Plumbing Prods. Liab. Litig., 644 F.3d 604 (8th Cir. 2011) (requires particularized injury for standing in product defect context)
- Union Pac. R.R. v. DHS, 738 F.3d 885 (8th Cir. 2013) (statutory reach of CAFA read with constitutional limits)
- DeBartolo v. Bennett, 485 U.S. 568 (1988) (Congress legislates with standing background; CAFA limited by Article III)
- Camp v. Ass’n of Data Processing Servs., 397 U.S. 150 (1970) (standing depends on injury and statutory rights)
- Bennett v. Spear, 520 U.S. 154 (1997) (Congress knows and respects constitutional standing limits)