Copley v. Natera, Inc.
- Yvonne Rogers
- 4:21-cv-08941
- U.S. District Court · Northern District of California
- 2
In Copley v. Natera, Judge Rogers ordered Elizabeth Copley to explain why her case should not be dismissed for lacking federal class-action jurisdiction.
Elizabeth Copley and her counsel were required to respond by May 18, 2022, or the case would be dismissed for lack of jurisdiction.
What happened
In Copley v. Natera, Inc., the court ordered Elizabeth Copley to explain why her claims should not be dismissed for failing to establish jurisdiction under the Class Action Fairness Act, or CAFA.
CAFA generally requires at least 100 class members, diversity between at least one class member and a defendant, and more than $5 million in controversy. Copley’s amended complaint did not identify the applicable jurisdictional provision and alleged only that more than $1 million was at stake, so the court found the jurisdictional allegation insufficient.
Judge Rogers gave Copley until May 18, 2022, to file a response of no more than six pages explaining why jurisdiction was proper and why the $5 million requirement was satisfied. The order warned that failing to respond on time would result in dismissal for lack of jurisdiction.
The detailed version
- Copley v. Natera, Inc. · No. 4:21-cv-08941
- Yvonne Rogers
- May 4, 2022
Background
Elizabeth Copley sued Natera, Inc. The First Amended Complaint alleged that the court had subject-matter jurisdiction under 28 U.S.C. § 1332 but did not specify which subsection applied. It also alleged that the amount in controversy exceeded $1 million, excluding interest and costs.
Jurisdictional issue
The court understood Copley to be invoking the Class Action Fairness Act (CAFA), which can give federal courts original jurisdiction over certain class actions. The order stated that CAFA requires at least 100 class members, at least one class member whose citizenship differs from that of a defendant, and an aggregate amount in controversy exceeding $5 million, excluding interest and costs. The party asserting federal jurisdiction bears the burden of establishing it.
Because the complaint alleged more than $1 million rather than the $5 million required by CAFA, and did not otherwise sufficiently identify the jurisdictional basis, the court found that Copley had not adequately alleged that the amount-in-controversy requirement was met.
Order
The court ordered Copley and her counsel to show cause in writing by May 18, 2022, why the claims should not be dismissed for failure to establish CAFA jurisdiction. The response could not exceed six pages. The court stated that failure to file a timely response would result in dismissal for lack of jurisdiction. This order required an explanation; it did not itself dismiss the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.