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Under CAFA, a district court has subject matter jurisdiction over any civil action in which the matter in controversy exceeds the sum or value of $5,000,000, exclusive of interest and costs, and is a class action in which any member of a class of plaintiffs is a citizen of a State different from any defendant. Additionally, the proposed class must consist of 100 persons or more. Also, federal courts have diversity jurisdiction if the parties are citizens of different states and the amount in controversy exceeds $75,000.
Plaintiff Gloria Hackman, a nurse as well as a public health and consumer watchdog, was a resident of the district of Columbia. She brought this suit alleging that defendant One Brands, LLC, misled its consumers when it sold them One Bars which were improperly labeled and marketed as low in sugar. Based on these and other alleged misrepresentations, plaintiff asserted a cause of action under the District of Columbia Consumer Protection Procedures Act (DCCPPA). As relief, plaintiff sought on behalf of the general public, an injunction against defendant including that it be barred from selling the product until the front of its labels give truthful information about the sugar content of the product. She also sought attorneys' fees and costs and punitive damages. Finally, plaintiff sought statutory damages on her own behalf. After this complaint was filed in superior court, defendant removed it to district court, and invoked the court's Class Action Fairness Act (CAFA) jurisdiction and traditional diversity jurisdiction, and filed a motion to dismiss the complaint on grounds of preemption, standing, and failure to state a claim for which relief may be granted. Plaintiff responded and later filed a motion to remand for lack of subject matter jurisdiction.
Did the district court lack subject matter jurisdiction over the case?
The court ultimately concluded that it did not have subject matter jurisdiction, thus, the Court granted plaintiff's motion to remand. The court held that it did not have jurisdiction to hear the case pursuant to CAFA since plaintiff has filed suit under the DCCPPA and has declined to pursue her claim as a class action. As such, CAFA did not apply. Also, the court held that defendant failed to establish that it met the amount in controversy requirement for diversity jurisdiction. The court then ordered this case be remanded to Superior Court. It also ordered that defendant's motion to dismiss be held in abeyance, to be resolved on remand.