Penrod v. K&N Engineering, Inc., No. 20-1355 (8th Cir. 2021)
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Plaintiffs, three individuals who purchased oil filters designed by K&N, seek to represent a nationwide class of all purchasers of three styles of K&N oil filters that they allege share a common defect, although most proposed class members had oil filters that never exhibited the alleged defect.
The Eighth Circuit affirmed the district court's finding that plaintiffs failed to plausibly allege the amount in controversy exceeded $5 million and therefore lacked jurisdiction under the Class Action Fairness Act. The court concluded that the class members whose oil filters never failed have not sustained injury or damages and cannot assist plaintiffs in meeting the $5 million jurisdictional threshold. Therefore, without these losses to aggregate, plaintiffs do not not plausibly allege an amount in controversy in excess of $5 million.
Court Description: [Erickson, Author, with Shepherd and Kobes, Circuit Judges] Civil case - Class Action Fairness Act. The district court did not err in determining that plaintiffs could not establish that the amount in controversy exceeded $5 million in the aggregate; the proposed class members whose K&N oil filters never failed have not sustained injury or damages and cannot assist plaintiffs in meeting the $5 million jurisdictional amount established by CAFA.
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