Wallace, et al. v. ConAgra Foods, Inc., No. 13-1485 (8th Cir. 2014)
Annotate this CasePlaintiffs, consumers, filed suit in Minnesota state court against ConAgra, claiming that some Hebrew National beef products were not, as the label reads, "100% kosher." ConAgra removed to federal court under the Class Action Fairness Act of 2005, 28 U.S.C. 1453. The district court decided that the First Amendment prohibited the courts from adjudicating plaintiffs' legal claims and dismissed the appeal. The court concluded that plaintiffs alleged economic harm - even if only a few pennies each - was a concrete, non-speculative injury. The court concluded, however, that plaintiffs' allegations failed to show that any of the particular packages of Hebrew National beef they personally purchased contained non-kosher beef. Without any particularized reason to think that plaintiffs' own packages of Hebrew National beef actually exhibited the alleged non-kosher defect, plaintiffs lacked Article III standing to sue ConAgra and CAFA did not extend federal jurisdiction to this case. The court vacated the district court's judgment, reversed the district court's dismissal with prejudice, and remanded with instructions to return this case to the state court for lack of federal jurisdiction.
Court Description: Civil case - Class Actions. In action by kosher meat consumers alleging defendant misrepresented the kosher status of its Hebrew National Kosher Beef products, including its Kosher hot dogs, the consumers lacked standing to bring the suit because consumers' allegations failed to show a particularized, actual injury in fact; CAFA does not extend federal jurisdiction to state law claims - if any exist - permitting recovery for bare statutory violations without any evidence the plaintiffs personally suffered a real, non-speculative injury in fact; the district court erred, however, in dismissing the case with prejudice, and the matter is remanded to the district court with instructions to return the case to the Minnesota state court for lack of federal jurisdiction.
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