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Home Depot U.S.A. Inc. v. Jackson

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Supreme Court of the United States
Home Depot U.S.A. Inc. v. Jackson
Term: 2018
Important Dates
Argument: January 15, 2019
Decided: May 28, 2019
Outcome
Affirmed
Vote
5-4
Majority
Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan
Dissenting
Samuel Alito • Chief Justice John G. Roberts • Neil Gorsuch • Brett Kavanaugh

Home Depot U.S.A. Inc. v. Jackson is a case argued before the Supreme Court of the United States on January 15, 2019, during the court's 2018-2019 term. The court affirmed the ruling of the United States Court of Appeals for the 4th Circuit, holding "Home Depot could not remove the class-action claim filed against it" because provisions in 28 United States Code §1441(a) and in the Class Action Fairness Act do not permit "removal by a third-party counterclaim defendant."[1] For more information, click here. The case came on a writ of certiorari to the 4th Circuit.[2]

HIGHLIGHTS
  • The case: In 2016, Citibank filed a debt collection action against George Jackson in a district court in North Carolina. Citibank alleged that Jackson failed to pay for a water treatment system he purchased using a Citibank-issued credit card. Jackson filed a counterclaim and third-party class action claims against Home Depot and Carolina Water Systems Inc. (CWS) for engaging in unfair and deceptive trade practices. Citibank then dismissed its claims against Jackson. Home Depot filed a notice of removal under the Class Action Fairness Act of 2005 (CAFA) and moved to realign the parties with Jackson as plaintiff and Home Depot, CWS, and Citibank as defendants. Jackson then amended his third-party complaint to remove Citibank. The district court denied Home Depot’s motion to realign and granted Jackson’s motion to remand.
  • The issue: Whether an original defendant to a class-action claim can remove the class action if it otherwise satisfies the jurisdictional requirements of the Class Action Fairness Act when the class action was originally asserted as a counterclaim against a co-defendant. The court also directed the parties to brief and argue the following question: Should this court’s holding in Shamrock Oil & Gas Corp. v. Sheets, 313 u. S. 100 (1941)–that an original plaintiff may not remove a counterclaim against it–extend to third-party counterclaim defendants?[3]
  • The outcome: The court affirmed the ruling of the United States Court of Appeals for the 4th Circuit, holding "Home Depot could not remove the class-action claim filed against it" because provisions in 28 United States Code §1441(a) and in the Class Action Fairness Act do not permit "removal by a third-party counterclaim defendant."[1]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • May 28, 2019: U.S. Supreme Court affirmed the 4th Circuit Court's ruling.
    • January 15, 2019: Oral argument
    • September 27, 2018: U.S. Supreme Court agreed to hear the case.
    • April 23, 2018: Petition filed with U.S. Supreme Court
    • January 22, 2018: Fourth Circuit Court affirmed district court’s ruling

    Background

    On June 9, 2016, Citibank filed a debt collection action against George Jackson in a district court in North Carolina. Citibank alleged that Jackson failed to pay for a water treatment system he purchased using a Citibank-issued credit card. On August 26, 2016, Jackson filed a counterclaim and third-party class action claims against Home Depot and Carolina Water Systems Inc. (CWS) for engaging in unfair and deceptive trade practices.[4]

    On September 23, 2016, Citibank dismissed its claims against Jackson. On October 12, 2016, Home Depot filed a notice of removal under the Class Action Fairness Act of 2005 (CAFA). Home Depot then moved to realign the parties with Jackson as plaintiff and Home Depot, CWS, and Citibank as defendants. Jackson then amended his third-party complaint to remove Citibank.[4]

    The district court denied Home Depot’s motion to realign. It ruled that there were not “antagonistic parties on the same side.” The court granted Jackson’s motion to remand, stating that Home Depot did not meet CAFA’s definition of “defendant.” The Fourth Circuit Court affirmed the ruling.[4]

    Home Depot appealed to the Supreme Court, and the court agreed to hear the case on September 27, 2018.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Whether an original defendant to a class-action claim can remove the class action if it otherwise satisfies the jurisdictional requirements of the Class Action Fairness Act when the class action was originally asserted as a counterclaim against a co-defendant.
    • The court also directed the parties to brief and argue the following question: Should this court’s holding in Shamrock Oil & Gas Corp. v. Sheets, 313 u. S.100 (1941) – that an original plaintiff may not remove a counterclaim against it- extend to third-party counterclaim defendants?

    Outcome

    In a 5-4 opinion, the court affirmed the judgment of the U.S. Court of Appeals for the 4th Circuit, holding "Home Depot could not remove the class-action claim filed against it" because provisions in 28 U.S. Code §1441(a) and in the CAFA do not permit "removal by a third-party counterclaim defendant."[1]

    Justice Clarence Thomas delivered the opinion of the court. He was joined by Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, and Elena Kagan. Justice Samuel Alito filed a dissenting opinion, joined by Chief Justice John Roberts and Justices Neil Gorsuch and Brett Kavanaugh.[1]

    Opinion

    In his opinion, Justice Thomas, referring to 28 U.S.C. §1441(a) and the CAFA, wrote:[1]

    “ In this case, we address whether either provision allows a third-party counterclaim defendant—that is, a party brought into a lawsuit through a counterclaim filed by the original defendant—to remove the counterclaim filed against it. Because in the context of these removal provisions the term "defendant" refers only to the party sued by the original plaintiff, we conclude that neither provision allows such a third party to remove. [5] ”

    Dissenting opinion

    Justice Alito filed a dissenting opinion, joined by Chief Justice Roberts and Justices Gorsuch and Kavanaugh.[1]

    In his dissent, Justice Alito wrote:[1]

    “ Today’s Court holds that third-party defendants are not "defendants." It holds that Congress left them unprotected under CAFA and §1441. This reads an irrational distinction into both removal laws and flouts their plain meaning, a meaning that context confirms and today’s majority simply ignores. [5] ”

    Text of the opinion

    Read the full opinion here.

    Audio

    Audio of oral argument:[6]

    Transcript

    Read the oral argument transcript here.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, Home Depot U.S.A. Inc. v. Jackson, May 28, 2019
    2. ↑ Supreme Court of the United States, "17-1471 Home Depot U.S.A. Inc. v. Jackson," accessed December 18, 2018
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-1471 Home Depot U.S.A. Inc. v. Jackson," accessed December 18, 2018
    4. ↑ 4.0 4.1 4.2 4.3 SCOTUSblog, "Home Depot U.S.A. Inc. v. Jackson," accessed December 18, 2018
    5. ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, Home Depot U.S.A. Inc. v. Jackson, argued January 15, 2019
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