Tanasi v. New Alliance Bank, No. 14-1389 (2d Cir. 2015)
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Plaintiff filed a putative class action against defendants and defendants subsequently offered to settle plaintiff's individual claims pursuant to Federal Rule of Civil Procedure 68 for an amount greater than the statutory damages to which plaintiff would have been entitled if successful. Plaintiff refused to accept and defendants filed a motion to dismiss. The district court denied the motion, holding that although plaintiff’s individual claims were rendered moot by the unaccepted Rule 68 offer, his putative class action claims were not. The court held that the district court maintained Article III subject matter jurisdiction over the case because, under the law of the Circuit, an unaccepted Rule 68 offer alone does not render a plaintiff’s individual claims moot before the entry of judgment against the defendants. Therefore, the district court maintained Article III subject matter jurisdiction over the case
regardless of plaintiff’s putative class action claims. Accordingly, because it is unnecessary to the disposition of this case, the court did not reach the certified question of whether putative class action claims brought under Rule 23 of the Federal Rules generally provide an independent basis for Article III justiciability. The court affirmed the district court’s decision that it maintained subject matter jurisdiction over the case, albeit on the alternative
ground that plaintiff's individual claims were not moot at the time the district court denied the defendants’ motion to dismiss.
The court issued a subsequent related opinion or order on May 21, 2015.
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