Rejecting Tele Aid, the Third Circuit in Maniscalco v. Brother Holds that the Laws of Consumers’ Home States Apply in Nationwide Class Actions

On March 8, 2013, the United States Court of Appeals for the Third Circuit issued its precedential decision in Maniscalco v. Brother International Corp., which significantly restricts the ability of out-of state plaintiffs to use the New Jersey Consumer Fraud Act (“NJCFA”) to pursue nationwide class actions in New Jersey against New Jersey based companies.