## Facts

- Greg Knowles filed a putative class action in Arkansas state court against Standard Fire Insurance Company on behalf of Arkansas homeowners insured under Standard Fire policies.
- The complaint alleged Standard Fire systematically underpaid covered losses by omitting general contractor fees from claim payments.
- Knowles sought to represent hundreds or thousands of policyholders and asserted aggregated class damages “no more than $5 million,” supported by an affidavit stipulating the class would seek less than $5 million.
- Standard Fire removed the case to federal court under the Class Action Fairness Act of 2005 (CAFA), which provides jurisdiction when aggregated class claims exceed $5 million.
- The district court found the aggregated amount in controversy would likely exceed $5 million absent the stipulation, but remanded based on the stipulation.
- The court of appeals declined discretionary review, and the Supreme Court granted certiorari.

## Issues

1. Whether a named plaintiff in a putative class action may defeat CAFA jurisdiction by stipulating, before class certification, that the class will seek less than $5 million in damages.

## Decision

- The Supreme Court vacated the remand order and remanded for further proceedings.
- A named plaintiff’s precertification stipulation limiting class damages below $5 million does not defeat CAFA jurisdiction because it cannot bind absent class members before certification.
- Federal courts must determine the amount in controversy by aggregating the claims of the proposed class members without treating a nonbinding stipulation as controlling.

## Legal Principles

- Stipulations bind the party who makes them, but a proposed class representative cannot bind absent class members before a class is certified.
- Under CAFA, the amount in controversy is assessed by aggregating the claims of individual class members; a nonbinding damages cap does not alter the aggregation analysis.
- Jurisdictional analysis at removal turns on the real value of the aggregated claims shown by evidence, not on an unenforceable unilateral limitation that depends on future certification outcomes.

## Conclusion

CAFA jurisdiction cannot be avoided through a precertification damages stipulation by the named plaintiff, because such a stipulation is not enforceable against absent class members and therefore does not control the aggregated amount in controversy.


Standard Fire Ins. Co. v. Knowles, 568 U.S. 588 (2013)