Term: 2002
Docket: 01-896
Ford Motor Company And Citibank (South Dakota), N. A. v. John B. Mccauley Et Al.
- Pro
01-896 FORD MOTOR CO. v. MCCAULEY Ruling below: CA 9, 264 F.3d 952. QUESTIONS PRESENTED I. Whether the cost to the defendant of complying with an injunction sought by a plaintiffs' class may satisfy the amount-in-controversy requirement of the diversity statute, where such compliance would cost the defendant more than the $75,000 minimum whether it covered the entire class or any single member of the class. 2. Whether, for purposes of applying the amount-in-controversy requirement of the diversity statute, a class action claim for punitive damages should be attributed to each member of the class as an undivided whole, or instead must be apportioned to each class member on a pro rata basis. CERT. GRANTED: 2/19/02 Limited to question 1 presented by the petition. ORDERED: 9/13/02 The parties are directed to file supplemental briefs addressing the following question: "Is there appellate jurisdiction when petitioners, as the nominally prevailing party in the district court, appeal the district court's dismissal of a complaint for lack of subject matter jurisdiction?"
In the case of Ford Motor Company and Citibank (South Dakota), N. A. v. John B. McCauley et al., 2002, the Supreme Court was asked to determine whether a federal law that allowed car leasing companies to pass on certain costs to consumers preempted state laws that prohibited such charges. The plaintiffs, John B McCauley and others had leased cars from Ford Motor Credit Company and were charged for excess wear and use upon termination of their leases, which they argued violated Rhode Island's state consumer protection laws. However, both Ford Motor Credit Company and Citibank claimed these charges were permissible under the Federal Consumer Leasing Act (FCLA). The court ruled in favor of McCauley stating that FCLA did not preclude states from setting stricter standards than those set by federal law.
In the dissenting opinion for Ford Motor Company and Citibank (South Dakota), N. A. v. John B. McCauley et al., Justice Stevens argued that the majority's decision to deny class certification was incorrect, as it failed to consider important factors such as commonality of claims among class members and typicality of representative parties' claims or defenses in relation to the entire class under Rule 23(a). He also criticized their interpretation of Rule 23(b)(3) which requires courts to find "that questions of law or fact common to class members predominate over any questions affecting only individual members." According to him, this rule does not necessitate a complete absence of individualized issues but rather demands a pragmatic assessment whether these issues are so substantial that they overwhelm shared ones, thus making a case unsuitable for resolution on behalf of all similarly situated plaintiffs at once.
