Smith v. Costa Del Mar, Inc.
3:18-cv-01011
M.D. Fla.Jun 17, 2025Background
- Plaintiff Troy Smith brought a class action against Costa Del Mar, claiming breach of warranty related to the Magnuson-Moss Warranty Act (MMWA).
- The action was filed in federal court, with Smith as the sole named plaintiff, relying on the Class Action Fairness Act (CAFA) as the jurisdictional basis.
- A class settlement was reached and approved by the district court, but objectors appealed, and the Eleventh Circuit reversed the approval, finding lack of standing for injunctive relief and ordering reconsideration of subject matter jurisdiction.
- Upon remand, the district court considered whether CAFA could provide federal jurisdiction for an MMWA class action with fewer than 100 named plaintiffs, given conflicting circuit opinions.
- Multiple recent circuit and district court decisions had held CAFA does not override the MMWA’s jurisdictional requirements, particularly the rule requiring at least 100 named plaintiffs for MMWA federal class actions.
- Ultimately, the district court dismissed the suit for lack of subject matter jurisdiction, permitting possible refiling in state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CAFA provides an independent basis for MMWA claims | CAFA grants jurisdiction despite MMWA limits | CAFA does not override MMWA; MMWA requirements control | CAFA is not an independent basis; MMWA limits apply |
| Whether a single plaintiff can bring an MMWA class action in federal court | Subsection (1)(A) allows it in any competent court (including federal) | Subsection (1)(A) does not permit single-plaintiff MMWA class actions in federal court | Court rejected (1)(A) as a basis for jurisdiction |
| If MMWA jurisdictional requirements are not met, can CAFA suffice for SMJ | CAFA should supersede MMWA requirements | CAFA cannot circumvent express MMWA restrictions | CAFA cannot replace MMWA's requirements |
| Effect of insufficient named plaintiffs for MMWA class action jurisdiction | Not a bar due to CAFA | Jurisdictional bar remains under MMWA | Case dismissed for lack of jurisdiction |
Key Cases Cited
- Smith v. Miorelli, 93 F.4th 1206 (11th Cir. 2024) (remanded to reconsider subject matter jurisdiction under MMWA and CAFA)
- Rowland v. Bissell Homecare, Inc., 73 F.4th 177 (3d Cir. 2023) (held CAFA does not provide jurisdiction for MMWA class actions that do not meet MMWA requirements)
- Floyd v. Am. Honda Motor Co., 966 F.3d 1027 (9th Cir. 2020) (CAFA cannot supersede express limitations of MMWA class action provisions)