Unreported / Non-Citable
Background
Montana residents brought a proposed class action against Meta Platforms, Inc. alleging that defectively designed social-media products harmed children. The proposed class covered Montana residents who were minors and used a Meta product from 2023 forward. The complaint asserted product-design, failure-to-warn, negligence, fraud, and Montana consumer-protection claims.
After removal from Montana state court, the case became part of the federal multidistrict litigation, or MDL, concerning adolescent addiction and personal injuries allegedly caused by social-media platforms. The plaintiffs asked the Northern District of California to return the suit to state court. Meta argued that federal jurisdiction existed both under ordinary diversity jurisdiction and under the Class Action Fairness Act, commonly called CAFA.
The parties agreed that the citizenship requirement was satisfied because the plaintiffs were Montana residents and the defendants were California residents. The dispute centered on the amount in controversy: more than $75,000 for an individual diversity case and more than $5 million in aggregate for the proposed class under CAFA.
The Court’s Holding
Chief Judge Yvonne Gonzalez Rogers denied remand and kept the action in federal court. The court found Meta’s jurisdictional estimates plausible in light of the complaint’s breadth, the proposed class of at least 100 Montana minors, and the damages sought for personal injuries allegedly tied to the same product features and conduct at issue in the broader coordinated litigation.
The court relied in part on the close parallel between the Montana allegations and claims already being litigated in the federal MDL and California’s coordinated state-court proceeding. It noted that a March 2026 bellwether verdict in the state proceeding awarded one individual plaintiff $3 million in compensatory damages and $3 million in punitive damages. Against that benchmark, the court reasoned that even one claimant could place more than $5 million in controversy, while a class of 100 or more members readily made Meta’s aggregate estimate plausible.
The plaintiffs did not identify materially different Meta products, conduct, or substantive legal rules unique to Montana. The court found the submitted Montana jury instructions similar to those considered in cases from other states and rejected an unsupported assertion that Montana discovery and procedural requirements warranted remand. It therefore concluded that Meta had adequately shown both the individual and CAFA jurisdictional thresholds.
Key Takeaways
- A defendant removing a class action under CAFA must plausibly allege more than $5 million in aggregate controversy and support that amount with evidence if challenged.
- Verdicts in closely related bellwether litigation can provide a concrete benchmark for evaluating the amount plausibly at stake.
- A broad class definition covering at least 100 minors, coupled with substantial personal-injury and punitive-damages allegations, can make the CAFA threshold readily supportable.
- State-specific procedure alone does not defeat federal subject-matter jurisdiction, particularly when the substantive claims and alleged product conduct mirror coordinated litigation elsewhere.
- Plaintiffs contesting removal should identify concrete differences in governing law, alleged conduct, or recoverable damages rather than relying on general assertions.
Why It Matters
For California lawyers handling nationwide consumer or product-liability class actions, the order shows how existing MDL and bellwether records can shape removal disputes. A prior verdict involving substantially similar allegations may supply persuasive evidence that the jurisdictional amount is met even before damages in the newly removed case have been developed.
The decision also reinforces that CAFA analysis focuses on what the complaint places at stake, not whether every class member will ultimately recover. Parties seeking a state forum need a fact-specific attack on the removing defendant’s assumptions; similarities to large coordinated proceedings may instead strengthen the case for federal jurisdiction.