The Magnuson-Moss Warranty Act provides for federal district court jurisdiction in cases alleging violations of that statute except where (1) any one claim is less than $25, (2) the total amount in controversy is less than $50,000, or (3) it is a class action with less than 100 named plaintiffs.
Several MMWA defendants have removed MMWA claims to federal district court that would fall within these carveouts, invoking the Class Action Fairness Act, which does not require 100 named plaintiffs for a class action to be removed to federal court.
The Third Circuit, agreeing with the Ninth Circuit and disagreeing with an unpublished decision from the Sixth Circuit, held that CAFA and the MMWA are irreconcilable, and thus, in a consolidated appeal, held that “CAFA does not provide a basis for federal jurisdiction over MMWA class actions that do not satisfy the MMWA’s jurisdictional requirements.”
