Juridical Link Doctrine Does Not Relax Article III Standing Requirements in Class Actions
In 6803 Boulevard East, LLC v. DIRECTV, LLC, the District of New Jersey rejected the notion that “the juridical link doctrine” provided a limited exception to Article III standing requirements in a class action against several related defendants and granted DirecTech’s motion for summary judgment because the named plaintiffs were not injured by DirecTech’s actions.
The juridical link doctrine, as articulated by the Ninth Circuit’s 1973 decision in La Mar v. H & B Novelty & Loan Co., provides that the typicality and adequacy-of-representation prongs of Rule 23(a) governing class certification may still be satisfied when the representative plaintiff has not been harmed by a particular defendant if “all defendants are juridically related in a manner that suggests a single resolution of the dispute would be expeditious.” In an opinion authored by Senior Judge William H. Walls, the New Jersey district court refused to extend the juridical link doctrine to issues of Article III standing.
In 6803 Boulevard East, the putative class action complaint alleged that each of the defendants installed satellite equipment on the plaintiffs’ property without their consent. But one of the defendants, DirecTech, never installed any satellite dishes on the plaintiffs’ properties. When DirecTech challenged the plaintiffs’ standing to sue based on the absence of harm caused by DirecTech, the plaintiffs argued that they could rely on the juridical link doctrine to establish standing, because all defendants are juridically related such that a single resolution would be expeditious.
Relying extensively on the Second Circuit’s Mahon v. Ticor Title Insurance Co., the court found “no sound basis for extending the doctrine” beyond Rule 23, because “whether or not Rule 23 would permit a plaintiff to represent a class against non-injurious defendants cannot affect the plaintiff’s Article III standing to sue.” In other words, “[a] federal rule cannot alter a constitutional requirement.” Accordingly, the court determined that “[b]ecause the parties agree that no named plaintiff has suffered injury at the hands of DirecTech, no named plaintiff has standing to pursue claims against DirecTech.”
Without binding authority to the contrary, it is likely that this opinion will be persuasive to any federal court in New Jersey addressing an argument that Article III standing exists based on the juridical link doctrine. As a result, a defendant facing a putative class action with multiple defendants in the District of New Jersey should ensure that the plaintiff or plaintiffs have adequately alleged an injury against each particular defendant.