Eleventh Circuit Vacates Cappuccitti Decision on CAFA Jurisdiction

The Eleventh Circuit acknowledged its error in interpreting the Class Action Fairness Act as providing federal court jurisdiction only if one plaintiff in the putative class action satisfies the amount in controversy requirement in 28 U.S.C. § 1331(a).  Readers will recall that we noted the Eleventh Circuit's error when the Cappuccitti decision first came out.  But what is still remarkable about this case is how any court could have reached such a conclusion in the first place.  Although the Class Action Fairness Act is not a model of clarity, it is not the statutory labyrinth that the Eleventh Circuit has made it out to be.  After all, courts must deal with much more Byzantine statutes such as ERISA.  If a court cannot interpret the relatively straightforward provisions of CAFA, what can we expect when it interprets more complex statutes?  Of course, the suggestion by the court that its error arose out of CAFA's complex nature is merely cover for an obviously embarrassed court.  Nevertheless, the court deserves a large amount of credit for remaining open-minded to the possibility that it committed significant error and having the judicial courage to vacate its decision rather than digging in its heels.