The Supreme Court of the United States announced decisions in two cases today:

Mississippi ex rel. Hood v. AU Optronics Corp., No. 12-1036: In a case implicating the Class Action Fairness Act of 2005 (CAFA), Petitioner Mississippi sued respondent LCD manufacturers in state court, alleging violations of state law and seeking restitution for LCD purchases made by the state itself and its citizens. Respondents removed the case to federal court, contending that the suit was a “mass action” removable under CAFA, i.e., a civil action “in which monetary relief claims of 100 or more persons are proposed to be tried jointly on the ground that the plaintiffs’ claims involve common questions of law or fact.” 28 U.S.C. §1332(d)(11)(B)(i). The District Court found that the suit was a mass action, but remanded to state court under CAFA’s “general public” exception, §1332(d)(11)(B)(ii)(III). The Fifth Circuit, in turn, reversed, finding the suit to be a mass action and the general public exception inapplicable. Today, the Court reversed and ordered remand to state court, holding that a suit filed by a State as the sole plaintiff, which includes a claim for restitution based on injuries suffered by the State’s citizens, does not constitute a “mass action” under CAFA.

The Court's decision is available here.

Daimler AG v. Bauman, No. 11-965: A number of Argentinian residents brought a complaint in California federal court against DaimlerChrysler Aktiengeselleschaft (Daimler), a German company that manufactures Mercedes-Benz automobiles in Germany. The complaint alleged that Daimler’s Argentinian subsidiary, Mercedes-Benz Argentina (MB Argentina) collaborated with state security forces during Argentina’s 1976-1983 “Dirty War” to kidnap, detain, torture, and kill certain MB Argentina workers. Jurisdiction in California was based on the California contacts of Mercedes-Benz USA, LLC (MBUSA), a Daimler subsidiary which was incorporated in Delaware, had its principal place of business in New Jersey, and distributed Daimler vehicles to independent dealerships in California and elsewhere in the United States. The District Court granted Daimler’s motion to dismiss for lack of personal jurisdiction. The Ninth Circuit reversed, holding that MBUSA fell within California’s all-purpose jurisdiction, and that MBUSA was Daimler’s agent for jurisdictional purposes such that Daimler was also subject to suit in California. The Court today reversed, holding that Daimler is not “at home” in California, and thus cannot be sued in that state for injuries plaintiffs attribute to MB Argentina’s conduct in Argentina.

The Court's decision is available here.