Yoon v. Meta Platforms, Inc.
- Nathanael Cousins
- 5:24-cv-02612
- U.S. District Court · Northern District of California
- 2
In Yoon v. Meta Platforms, Inc., Judge Cousins ordered Meta to show by December 13 why the proposed class has at least 100 people for federal jurisdiction.
The order directly affects Meta Platforms, Inc., which must submit a written response addressing whether the proposed class has at least 100 people. It also affects the plaintiffs because the case’s continued federal jurisdiction may depend on that showing.
What happened
Yoon v. Meta Platforms, Inc. concerns whether the federal court has jurisdiction under the Class Action Fairness Act, a law allowing certain large class actions in federal court. The court focused on whether the proposed class includes at least 100 people.
The plaintiffs’ complaint did not state a specific class size. Meta argued that the class must include at least 100 people because the plaintiffs alleged there were at least 40 members and that the actual number was likely in the thousands. Meta did not provide evidence or explain how it reached that estimate.
Judge Nathanael M. Cousins ordered Meta to show in writing by December 13, 2024, why the case meets the 100-person requirement. The order did not finally decide whether the court has jurisdiction or resolve the underlying claims.
The detailed version
- Yoon v. Meta Platforms, Inc. · No. 5:24-cv-02612
- Nathanael Cousins
- Dec. 6, 2024
Background
The court examined whether this proposed class action satisfies the Class Action Fairness Act (CAFA), which can give federal district courts jurisdiction over certain class actions. The court stated that CAFA requires, among other things, at least 100 proposed plaintiffs, citizenship by at least one class member different from that of at least one defendant, and more than $5 million in dispute.
Because the complaint did not allege a specific class size, the court said Meta, as the party relying on federal jurisdiction, had to prove by a preponderance of the evidence that the proposed class contains at least 100 people. The court explained that this requires sufficient, nonconclusory evidence.
Court’s Analysis
The plaintiffs alleged that there were at least 40 members of the proposed class, while stating that the true number was almost certainly higher. Meta argued that the class therefore consisted of at least thousands of people, and likely many more. The court found that statement conclusory because Meta provided no evidence supporting the increase from 40 to thousands and no explanation of how it calculated the estimate.
Ruling
The court ordered Meta to show cause in writing by December 13, 2024, why the case has the required 100-person numerosity for federal jurisdiction under CAFA. This is an order requiring a response; the opinion does not state that the court dismissed the case, finally resolved jurisdiction, or decided the merits of the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.