WASHINGTON, D.C. - A state's lawsuit seeking restitution for itself and its citizens, in which it is the only named plaintiff, does not qualify as a mass action under the Class Action Fairness Act (CAFA), the U.S. Supreme Court ruled unanimously on Jan. 14 (State of Mississippi, ex rel. Jim Hood, Attorney General v. AU Optronics Corp., et al., No. 12-1036, U.S. Sup.; 2014 U.S. LEXIS 645).