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Supreme Court hears arguments on class actions, federal and state laws

The US Supreme Court [official website] heard arguments in two cases [JURIST report] on Monday. The first, Descamps v. United States [transcript, PDF], concerned whether Matthew Descamps' burglary conviction under California law can allow a conviction under federal burglary law, which had slightly different requirements than California's statute. Federal judges used the "modified categorical approach" and looked at a limited number of documents to determine that Descamps was convicted of the elements of the generic crime under federal law. Thus, when Descamps was convicted of a federal felony, the government then translated his previous California crime to a federal one to increase his sentence under the Armed Career Criminal Act [text] (ACCA). Descamps' attorney argued that his client was deprived of having the federal crime proven beyond a reasonable doubt, and that the elements of California burglary are too removed from the federal elements, which were set out by the the US Court of Appeals for the Eighth Circuit in Taylor v. US [opinion]. "In California, burglary—unlawful entry as defined by the Court in Taylor on what a generic burglary consists of, is not an element of California burglary. Any entry with the intent to commit a crime, a theft, or a felony will do. A California jury is never required to actually find unlawful entry in the Taylor sense." The United States government argued that, since Descamps pleaded guilty, he pleaded guilty to the generic crime of burglary, not the elements. "It's an unworkable distinction, because, from—from the point of view of the defendant pleading guilty, whether it's an alternative element or an alternative means, it's just an alternative way of offering the factual basis for the crime. And the sentencing court ought to look, as the Court, as this Court said in Shepard, to the factual basis that's offered for pleading guilty."

In The Standard Fire Insurance Co. v. Knowles [transcript, PDF] the court heard its first case on the Class Action Fairness Act (CAFA) [PDF], which put a number of class actions under federal jurisdiction. At issue here is whether, under the act, a class can avoid having a suit moved to federal court if it keeps the amount in controversy [28 USC § 1332] under $75,000 for each plaintiff. The Standard Fire Insurance Co. argued that the court must consider the plaintiffs' potential earnings in aggregate, and that Congress intended for the CAFA to avoid these sorts of abuses. "The Congress was very concerned that cases were being kept in the State courts through abuses and manipulations of the amount in controversy. It's very clear in the Senate report, Congress talks about this because, for example, in this case the defendants can never get a class certification hearing in Miller County." The attorney for Greg Knowles and the class he represents argued that "[o]ur position is that the stipulation is binding throughout the 'civil action filed by the putative class representative.' I want to focus on the words 'civil action' because there has been no civil action filed by any absent class members. The only civil action that the district court is being considered for jurisdiction is the civil action that has been filed by the putative class representative. So if the class is later not certified, the stipulation would only bind the putative class representative."

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