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No. CV 18-2101
tl;dr:
To calculate the amount in controversy for diversity jurisdiction, claims brought on behalf of multiple people may not be added together to meet the amount.Case Summary
In the 2019 case of Hackman v. One Brands, Gloria Hackman sued One Brands for allegedly lying about the sugar content in its protein bars, violating the D.C. Consumer Protection Procedures Act. Hackman, a nurse and consumer advocate, wanted the company to stop selling the bars until they were correctly labeled or changed, and sought damages and legal fees.
One Brands tried to move the case to federal court, claiming class action and diversity jurisdiction. However, Hackman argued that it should stay in state court because there was no federal jurisdiction. The district court agreed with Hackman, stating that the Class Action Fairness Act didn't apply since this was a public interest case, not a class action. The court also found no diversity jurisdiction because One Brands couldn't prove the amount in dispute was over $75,000.
The court dismissed One Brands' claims that the cost of fixing the issue, potential damages, and legal fees could meet the jurisdictional threshold, stating that these amounts were speculative and couldn't be added together for multiple plaintiffs under the non-aggregation principle.
This case is significant because it shows how courts decide jurisdiction in removal cases based on each case's unique details and balances enforcing state consumer protection laws with preventing forum shopping. Additionally, it highlights how courts determine if a case is a class action or public interest action, and the possible remedies for false advertising allegations.
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