In Standard Fire Ins. Co. v. Knowles, 133 S. Ct. 1345 (2013), the Supreme Court unanimously held that a stipulation filed with a class action complaint stating that damages will be limited to under $5 million must be ignored and thus cannot be used to avoid federal jurisdiction under the Class Action Fairness Act of 2005 (CAFA). While the Court did not specifically address what standard of proof applies to the amount in controversy in a CAFA case, the Court may have changed the law on what the burden of proof is regarding CAFA’s $5 million jurisdictional minimum, making it considerably easier for defendants to establish that the jurisdictional threshold has been met, regardless of a plaintiff’s attempt to plead below it.
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