Ford Motor Co. v. McCauley

McCauly represents a class of plaintiffs who brought suit against Ford Motor Co. and Citibank alleging various state law actions arising from Ford’s cancellation of a rebate program associated with the Ford/Citibank credit card. Six state actions in six separate states were filed. Ford removed these actions to federal court on the basis of diversity jurisdiction and then petitioned the Judicial Panel on Multidistrict Litigation to consolidate and transfer the cases to a single district for pre-trial proceedings. After consolidation, the district court sua sponte issued an order to show cause why the action should not be dismissed for failure to state a claim in excess of $75,000 in the consolidated complaint. The district court dismissed the action for lack of subject matter jurisdiction and remanded the cases to state court. The court of appeals affirmed, holding that plaintiffs did not have a claim for the requisite jurisdictional amount on the basis of compensatory or punitive damages, injunctive relief, or disgorgement.

Question Presented:
Whether the cost to the defendant of complying with an injunction sought by a plaintiffs’ class may satisfy the amount-in-controversy requirements of the diversity jurisdiction statute, where such compliance would cost the defendant more than the $75,000 jurisdictional amount whether it covered the entire class or any single member of the class.

Decision under Review

Supreme Court opinion