Polaris Industries Inc., et al. v. Jeremy Albright

Federal courts have a strict duty to exercise the jurisdiction Congress confers upon them, including the jurisdiction conferred by the Class Action Fairness Act of 2005, 28 U.S.C. §§1332, 1453, 1711-15, (“CAFA”). Nevertheless, the Ninth Circuit held in this case that if a class action plaintiff asserting a claim for equitable relief has an adequate legal remedy, a federal district court cannot reject the claim on the merits but must instead decline CAFA jurisdiction, dismiss the claim without prejudice, and allow it to be re-filed in state court, because of a lack of “equitable jurisdiction.” That erroneous decision creates a new and unauthorized abstention doctrine, forces claim splitting, departs from near-uniform circuit consensus about the subject-matter jurisdiction conferred by CAFA, and contravenes Congress’s efforts to prevent forum shopping and class action abuse. The question presented is: Whether CAFA’s mandatory grant of subject matter jurisdiction and enumeration of limited equitable bases authorizing abstention require district courts with CAFA jurisdiction to reach the merits of an equitable claim rather than dismissing it for refiling in state court based on a lack of “equitable jurisdiction.”