Saskatchewan Mutual Ins. Co. v. CE Design, Ltd.

Dist. Ct. did not err in dismissing for lack of jurisdiction plaintiff-insurance company’s action against defendant-class action representative seeking to enforce Canadian judgment that rejected defendant’s attempt to enforce $5 million judgment obtained by class representative in prior Illinois state court action, after Canadian court found that plaintiff, who was insurance carrier of defendant in Illinois action, had not received sufficient notice of Illinois judgment. Neither of two possible bases for jurisdiction, i.e., Class Action Fairness Act (CAFA) or alienage branch of diversity jurisdiction, applied, where: (1) CAFA applies only where plaintiff is class action and not when class action is defendant; and (2) no class member could satisfy $75,000 amount in controversy requirement for purposes of establishing diversity jurisdiction because underlying class action concerned class members’ receipt of 23,521 unsolicited fax communications, and no exceptions to general prohibition on aggregation of claims applied.