Mississippi Ex Rel. Hood v. AU Optronics Corp.
134 S. Ct. 736
| SCOTUS | 2014Background
- CAFA expands federal jurisdiction for class and mass actions; mass action defined as monetary-relief claims of 100+ persons proposed to be tried jointly on common questions of law or fact.
- Mississippi filed a state-court suit against AU Optronics and others alleging antitrust/consumer-protection violations and seeking restitution for LCD purchases by the State and its citizens.
- District Court held it did not qualify as a class action but did qualify as a mass action, invoking CAFA’s general public exception to remand to state court.
- Fifth Circuit affirmed mass-action status but vacated remand denial, and the Supreme Court granted certiorari to resolve whether a State-led suit with restitution claims can be a mass action.
- The Court held that Mississippi, as the sole named plaintiff, cannot be a mass action under CAFA; 100+ persons must be named plaintiffs for mass action status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CAFA’s mass action covers 100+ unnamed persons | Hood: unnamed real parties in interest count toward 100+ | AU Optronics: unnamed parties should count | No; mass action requires 100+ named plaintiffs |
| Whether 'plaintiffs' includes unnamed real parties in interest | Hood: 'plaintiffs' includes unnamed beneficiaries | AU Optronics: restrict to named plaintiffs | No; only named plaintiffs counted |
| Whether courts may pierce pleadings to identify real parties in interest for mass action | Hood: background inquiry should apply to ensure proper numerosity | AU Optronics: background inquiry not applicable to mass action | No; CAFA displacement of background real-party inquiry |
Key Cases Cited
- Brown v. Gardner, 513 U.S. 115 (1994) (statutory interpretation and consistency in term usage)
- Griffin v. Oceanic Contractors, Inc., 458 U.S. 564 (1982) (textual consistency and congressional intent in statutorily defined terms)
- Wecker v. National Enameling & Stamping Co., 204 U.S. 176 (1907) (look-behind diversity inquiry in jurisdictional analysis)
- Caldwell v. Allstate Insurance Co., 536 F.3d 418 (CA5 2008) (background real-party-in-interest inquiry in diversity contexts)