On March 4, Bryan Weintrop and Adel Kelifa published “Recalibrating equitable jurisdiction in federal court: The 9th Circuit’s post-Sonner landscape” in the Daily Journal. The following is an excerpt:
Recent 9th Circuit decisions have clarified the procedural landscape with respect to jurisdictional issues impacting California consumer class actions. Specifically, these recent decisions have clarified how federal courts may exercise jurisdiction over claims seeking equitable relief in the wake of the 9th Circuit’s 2020 decision in Sonner v. Premier Nutrition Corp., 971 F.3d 834 (9th Cir. 2020)–which held that dismissal of claims seeking equitable relief is appropriate where the plaintiff possesses an adequate legal remedy (i.e., monetary damages)–and offer defendants new strategic choices when evaluating whether to assert an absence of equitable jurisdiction as a defense.
In Sonner, a California district court dismissed a plaintiff’s amended complaint without prejudice after the plaintiff voluntarily dismissed her sole state-law damages claim and elected to proceed only on state-law claims seeking equitable relief under the California Unfair Competition Law (UCL) and Consumers Legal Remedies Act (CLRA) for restitution and injunctive relief. The 9th Circuit affirmed, holding that the plaintiff’s inability to establish the absence of an adequate remedy at law (potential monetary damages) required dismissal due to a lack of equitable jurisdiction.
Central to the 9th Circuit ’s reasoning was the principle that “even if a state authorizes its courts to provide equitable relief when an adequate legal remedy exists, such relief may be unavailable in federal court because equitable remedies are subject to traditional equitable principles unaffected by state law.” Following Sonner, defendants began relying on this holding to strategically attempt to obtain dismissal of equitable claims pending in federal court due to the availability of an adequate remedy at law.
However, in response to such dismissals—without prejudice—plaintiffs often attempted to refile such claims in state court, only for defendants to again remove the action to federal court, resulting in a procedural loop of state court filings, removals and dismissals.
For the full article, click here.