Class Actions, CAFA, Relationship to Magnuson-Moss Warranty Act Jurisdictional Requirements, 2, 7

CAFA does not impliedly repeal the Magnuson-Moss Warranty Act’s limitations on federal court jurisdiction.  For a federal court to have jurisdiction of a class action claim under the MMWA, there must be at least 100 named plaintiffs.  15 USC 2310(d)(3).  An MMWA class action claim brought by fewer than 100 named plaintiffs must proceed in state court.  CAFA cannot be used to evade or override the MMWA’s specific numerosity requirement.  However, the district court may exercise CAFA jurisdiction over appended state law claims if CAFA’s jurisdictional requirements are otherwise satisfied.