Standard Fire Insurance Company v. Knowles (2012)
- Docket
- 11-1450
- Decided
- 2012-01-01
Summary
Question: Can a plaintiff in a class action case stipulate that the potential damages are less than $5 million, which removes the case from federal jurisdiction? Conclusion: No. Justice Stephen G. Breyer, writing for a unanimous court, vacated the lower court decision and remanded. To defeat jurisdiction the stipulation must be binding, and a plaintiff bringing a proposed class action cannot bind members of the proposed class before the class is certified. Knowles only has the authority to bind himself to a stipulated claim amount. Federal jurisdiction cannot be based on contingent future events, and the non-binding stipulation may not survive the certification process. For example, the complaint may clearly show an amount in controversy over $5 million, Knowles may be an inadequate class representative, or another party might intervene with an amended complaint. Individual plaintiffs may control jurisdiction through stipulation, but a named plaintiff in a not yet certified class action cannot.