Robert Leflar v. Target Corporation, No. 22-3468 (8th Cir. 2023)Annotate this Case
Plaintiff bought a laptop with a manufacturer’s warranty from Target. He filed a class action on behalf of “all citizens of Arkansas who purchased one or more products from Target that cost over $15 and that were subject to a written warranty.” His theory was that Target violated the Magnuson-Moss Warranty Act’s Pre-Sale Availability Rule by refusing to make the written warranties reasonably available, either by posting them in “close proximity to” products or placing signs nearby informing customers that they could access them upon request. Target filed a notice of removal based on the jurisdictional thresholds in the Class Action Fairness Act of 2005. The district court the class action against Target Corporation to Arkansas state court.
The Eighth Circuit vacated the remand order and return the case to the district court for further consideration. The court explained that the district court applied the wrong legal standard. The district court refused to acknowledge the possibility that Target’s sales figures for laptops, televisions and other accessories might have been enough to “plausibly allege” that the case is worth more than $5 million. The district court then compounded its error by focusing exclusively on the two declarations that accompanied Target’s notice of removal. The court wrote that the district court’s failure to consider Target’s lead compliance consultant’s declaration, Target’s central piece of evidence in opposing remand, “effectively denied” the company “the opportunity . . . to establish [its] claim of federal jurisdiction.”
Court Description: [Stras, Author, with Erickson and Melloy, Circuit Judges] Civil case - Class Action. The district court did not apply the correct standard in evaluating whether the amount in controversy met the requirement for removal of a class action; under the Class Action Fairness Act there is no anti-removal presumption, much less a requirement to resolve all doubts about federal jurisdiction in favor of remand; the district court's failure to consider the post-removal declaration of Target's lead compliance consultant that the law suit would require Target to spend over $7.5 million if plaintiff prevails, effectively denied the company the opportunity to establish its claim of federal jurisdiction; the district court's remand order is vacated, and the matter is remanded to the district court for further consideration. [ January 06, 2023 ]