But, then and now, there were other equitable remedies-including some that result in monetary compensation-and the lines were not always sharply drawn. XI.Īs a general matter, actions at law sought money damages while actions in equity sought injunctions or similar orders that compelled or prohibited actions. And the Eleventh Amendment restricted the judicial power from reaching "any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State." U.S. The Seventh Amendment right to a trial by jury in a civil case extended only to "suits at common law," saying nothing of equity. Article III defined the "judicial power" to "extend to all Cases, in Law and Equity" that fell into certain categories. The Constitution, too, recognized the distinction between actions at law and actions in equity. McCormick, The Fusion of Law and Equity in United States Courts, 6 N.C. By the time of the drafting of the Constitution, England had developed two relevant court systems: the courts of law and courts of equity. To explain the resolution of this motion, a little history is necessary. The plaintiffs argue that this case must be remanded to state court because I lack equitable jurisdiction over it. This motion, however, is not about the allegations of the suit, it is about the fact that the plaintiffs seek only equitable relief under the UCL. This, the plaintiffs claim, would incorrectly lead consumers to believe they were only paying the amount of the premium they would be paying for the underlying policy, which is not true. It alleges, essentially, that Transamerica represented that policy riders for its insurance policies would have "no charge." Id. The Complaint brings three claims, all under the UCL, and seeks only equitable restitution. Plaintiffs Brian Guthrie and Grady Lee Harris, Jr., filed this putative class action against Transamerica Life Insurance Company ("Transamerica") in California state court Transamerica removed it to this court in June 2021. Them to dismiss or stay the case that power, the Court explained, arises from a federal court's authority "to decline to exercise its jurisdiction when it is asked to employ its historic powers as a court of equity." Because I lack equitable jurisdiction over the plaintiffs’ claims, their motion to remand the case to state court is granted. 1712, 135 L.Ed.2d 1 (1996), the Court held that federal courts may remand cases when an abstention doctrine would require Three decades later, the Court reiterated the principle in Twist v. 804 (1893), the Court held that when a federal court lacks equitable jurisdiction over a removed case, the case may be remanded, not dismissed. While neither I nor the parties have found a case deciding this issue based on Sonner, United States Supreme Court precedent squarely favors the plaintiffs.īefore the turn of the last century, in Cates v. But this case started in state court and was removed to this court, so the plaintiffs argue that I should remand it because the state court is not bound by federal equitable rules. Often, when a federal court finds that it lacks equitable jurisdiction, it dismisses the claim or request for relief. Under Sonner, then, I lack equitable jurisdiction over the plaintiffs’ claims. The plaintiffs in this case do not plead that they lack legal remedies in fact, they represent that they will not and cannot do so. District courts have understood Sonner to require that, at a minimum, a plaintiff plead that she lacks an adequate remedy at law. 2020), that traditional federal equitable rules apply to UCL restitution in particular, a plaintiff must demonstrate that she lacks an adequate remedy at law before securing UCL restitution. Last year, the Ninth Circuit held in Sonner v. The plaintiffs seek a single remedy under a single statute: equitable restitution under California's Unfair Competition Law ("UCL"). This case presents an issue that is both novel and settled by a century-old principle. Wendy Enerson, Pro Hac Vice, Cozen O'Connor, Chicago, IL, Alicia Marie Gurries, Cozen O'Connor, San Francisco, CA, Valerie Diane Rojas, Cozen O'Connor, Los Angeles, CA, for Defendant. Benjamin Blakeman, Attorney at Law, Beverly Hills, CA, for Plaintiffs. Lison, Feinstein Doyle Payne & Kravec, LLC, Pittsburgh, PA, J.
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