Standard Fire Ins. Co. v. Knowles (Standard Fire Ins. Co. v Knowles)

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2013 United States Supreme Court case

Standard Fire Insurance Co. v. Knowles, 568 U.S. 588 (2013), was a United States Supreme Court case in which the court held that a class-action plaintiff cannot defeat federal court jurisdiction by stipulating that they will not seek damages above the amount-in-controversy requirement.

Background

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The Class Action Fairness Act of 2005 (CAFA) gives federal district courts original jurisdiction over class actions in which the matter in controversy exceeds $5 million in sum or value, and it provides that to determine whether a matter exceeds that amount the "claims of the individual class members must be aggregated." When Knowles filed a proposed class action in Arkansas state court against Standard Fire Insurance Company , he stipulated that he and the class would seek less than $5 million in damages. Pointing to CAFA, Standard Fire removed the case to the federal District Court, but it remanded to the state court, concluding that the amount in controversy fell below the CAFA threshold in light of Knowles's stipulation, even though it found that the amount would have fallen above the threshold absent the stipulation. The Eighth Circuit Court of Appeals declined to hear Standard Fire's appeal.