Home Depot U. S. A., Inc. v. Jackson
2019 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Home Depot U. S. A., Inc. v. Jackson, 587 U.S. ___ (2019), was a United States Supreme Court case which determined that a third-party defendant to a counterclaim submitted in a state-court civil action cannot remove their case to federal court. The Court explained, in a 5–4 decision, that although a third-party counterclaim defendant is a "defendant to a claim," removal can only be performed by the defendant to a "civil action."[1] And this holds true even when the counterclaim is in the form of a class action. The Class Action Fairness Act of 2005 permits removal by "any defendant to a class action" but this does not extend removal rights to a third-party counterclaim defendant because they are not a defendant to the original case.[2][3]
Home Depot U. S. A., Inc. v. Jackson | |
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Argued January 15, 2019 Decided May 28, 2019 | |
Full case name | Home Depot U. S. A., Inc., Petitioner v. George W. Jackson |
Docket no. | 17-1471 |
Citations | 587 U.S. ___ (more) 139 S. Ct. 1743 |
Argument | Oral argument |
Decision | Opinion |
Holding | |
Federal law does not authorize the removal of a case to federal court by a third-party counterclaim defendant, even where the counterclaim is a class action. | |
Court membership | |
| |
Case opinions | |
Majority | Thomas, joined by Ginsburg, Breyer, Sotomayor, Kagan |
Dissent | Alito, joined by Roberts, Gorsuch, Kavanaugh |
Laws applied | |
28 U.S.C. §1441, Class Action Fairness Act of 2005 |
Although the decision technically only governs what court hears—rather than the actual outcome of—a particular case, the ruling has been described as being "pro-consumer" because of its potentially broader implications.[4] The practical effect of the Court's holding is to make it "more difficult for class action defendants to transfer their cases from plaintiff-friendly state courts to more business-friendly federal courts."[4] As such, while the case theoretically only deals with venue, it may in practice benefit consumers with plausible claims against corporations.
Justice Samuel Alito, in the dissenting opinion, argued that a plaintiff who brings a lawsuit in their "own state's courts might ... enjoy ... a home court advantage against outsiders."[5] To that end, he explained, Congress opened the "federal courts to certain disputes between citizens of different states."[5] While plaintiffs could take this option by simply filing their case in federal court, defendants did not have control over where a case was filed. So defendants were given the right of removal, which could be invoked to transfer a case from state to federal court. By denying removal here, Justice Alito argued, the majority had denied the defendant a "neutral forum."[5]