Transamerica Retirement Solutions, LLC v. Gloria A. Addison, et al.

The Class Action Fairness Act of 2005 (CAFA) expanded federal diversity jurisdiction over large-scale civil lawsuits to “ensur[e] Federal court consideration of interstate cases of national importance.” Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 89 (2014). CAFA provides for federal jurisdiction over most class actions that satisfy minimal diversity and have an amount in controversy greater than $5 million. 28 U.S.C. § 1332(d)(2)-(10). CAFA also mandates that any lawsuit filed by 100 or more plaintiffs involving common questions of law or fact—a “mass action”—be treated the same as a class action for purposes of federal jurisdiction. 28 U.S.C. § 1332(d)(11)(A). A narrow exception exists where all of the claims in the mass action arise from “an event or occurrence” in the state where the lawsuit was filed and all of the alleged injuries occur in that state or contiguous states. 28 U.S.C. § 1332(d)(11)(B)(ii). The circuits have repeatedly split over the meaning of this “local single event” exception and the proper interpretation of “an event or occurrence.” The question presented is: Whether the phrase “an event or occurrence” in CAFA’s local single event exception means what it says—“a single happening”—as the Ninth Circuit holds, or can it encompass an entire pattern or series of events occurring over a period of years, as the Third, Fifth, and Eleventh Circuits hold.