Term: 2018
Docket: 17-1471
Home Depot U.s.a. Inc. v. Jackson
- Pro
17-1471 HOME DEPOT U.S.A., INC. V. JACKSON DECISION BELOW: 880 F.3d 165 IN ADDITION TO THE QUESTIONS PRESENTED BY THE PETITION, THE PARTIES ARE DIRECTED TO BRIEF AND ARGUE THE FOLLOWING QUESTION: SHOULD THIS COURT’S HOLDING IN SHAMROCK OIL & GAS CORP. V. SHEETS, 313 U. S. 100 (1941) – THAT AN ORIGINAL PLAINTIFF MAY NOT REMOVE A COUNTERCLAIM AGAINST IT- EXTEND TO THIRD-PARTY COUNTERCLAIM DEFENDANTS? CERT. GRANTED 9/27/2018 QUESTION PRESENTED: This action was commenced when Citibank, N.A. filed a routine state-court collection action against respondent George W. Jackson. Petitioner Home Depot U. S. A., Inc. was not a party to that action and never became a party to that collection dispute. Jackson then filed a counterclaim against Citibank asserting class-action consumer-protection claims. In addition to naming Citibank, Jackson named Home Depot and another company as original defendant to that counterclaim class action. The Class Action Fairness Act of 2005, Pub. L. No. 109-2, 119 Stat. 4, permits "any defendant in a state-court class action to remove the action to federal court if it satisfies certain jurisdictional requirements. Petitioner Home Depot is an original defendant in the class action at issue here and was never a plaintiff in any claim associated with this case. The question presented is: Whether an original defendant to a class-action claim can remove the class action if it otherwise satisfies the jurisdictional requirements of the Class Action Fairness Act when the class action was originally asserted as a counterclaim against a co-defendant. LOWER COURT CASE NUMBER: 17-1627
The U.S. Supreme Court case Home Depot U.S.A. Inc v. Jackson, 2018 revolved around the question of whether a third-party counterclaim defendant can remove claims to federal court under the general removal statute or the Class Action Fairness Act (CAFA). The dispute began when Citibank filed a debt collection action against George W. Jackson in North Carolina state court and later added Home Depot as a defendant after it was alleged that they were involved in an unlawful scheme with two other companies regarding water treatment systems sold by them through predatory lending practices and deceptive sales tactics. In response, Home Depot sought to move the case from state to federal court under CAFA but was denied by both district and appeals courts on grounds that neither law allowed for such removals by third-party defendants like itself. In May 2019, this decision was upheld by the Supreme Court which ruled 5-4 against Home Depot stating that only original defendants have permission to shift lawsuits from state courts into federal ones according to current laws; not parties brought into cases via claims filed by original defendants.
In the dissenting opinion for HOME DEPOT U.S.A. INC. v. JACKSON, Justice Alito argued that the majority's interpretation of federal law was incorrect and inconsistent with precedent. He contended that Home Depot should have been allowed to remove a class-action claim from state court to federal court because it was not an original defendant in the case but rather became involved later as a third-party counterclaim defendant brought into the suit by another party who had been sued by Jackson initially. According to him, this reading is more consistent with Congress’s intent when drafting removal statutes and better aligns with previous Supreme Court interpretations of these laws.
