Opinion · Court of Appeals for the Ninth Circuit

Tanoh v. Dow Chemical Co.

561 F.3d 945

Type
Opinion
Court
Court of Appeals for the Ninth Circuit
Jurisdiction
Federal
Date
2009-09-09
Topic
litigation

How later courts describe this case

  • holding that CAFA’s requirement of 100 or more plaintiffs refers only to actual, named plaintiffs
  • noting that the “wellestablished presumption against federal removal jurisdiction” is applicable in the CAFA context
  • noting that “CAFA’s class action provisions are completely silent” about claim splitting to avoid the jurisdictional amount
  • agreeing with the district court that plaintiffs had not “‘strategically sought to avoid federal jurisdiction’ by filing several separate state court actions in groups fewer than one hundred”
  • rejecting “the general proposition that plaintiffs’ lawyers cannot ‘game’ the system by artificially structuring their suits so as to avoid CAFA jurisdiction” in the context of CAFA’s “mass action” provisions
  • APlaintiffs= separate state court actions may, of course, become removable at some later point if plaintiffs seek to join the claims for joint trial.@
  • “[W]e cannot sensibly eiitertain the notion that Congress intended to allow courts to override the considered legislative limitations on the ‘mass action’ concept.”
  • plaintiffs filed actions containing fewer than 100 plaintiffs but aggregating to more than 100 plaintiffs, but neither plaintiffs nor the state court had proposed consolidating the actions for trial; CAFA jurisdiction absent

Citator

UpLaw has not yet analyzed Tanoh v. Dow Chemical Co.. The absence of a flag is not a finding that it is good law.

Cited by
77 opinions