Mims v. Arrow Financial Services, LLC

Summary

The Supreme Court held that federal district courts have concurrent jurisdiction with state courts over private actions arising under the Telephone Consumer Protection Act (TCPA). The TCPA's authorization for private plaintiffs to sue in an appropriate state court did not expressly or implicitly displace federal-question jurisdiction under 28 U.S.C. § 1331. The Court reversed the Eleventh Circuit and remanded the case.

Holdings

1. Federal and state courts have concurrent jurisdiction over private actions arising under the Telephone Consumer Protection Act. The TCPA's authorization to bring a private action in an appropriate state court does not expressly or by fair implication divest federal district courts of jurisdiction under 28 U.S.C. § 1331.
2. Congress did not eliminate or displace § 1331 jurisdiction over private TCPA actions.

Questions Presented

1. Whether Congress's authorization of private TCPA actions in an appropriate state court makes state courts the exclusive forum for those actions.
2. Whether federal district courts retain federal-question jurisdiction under 28 U.S.C. § 1331 over private actions arising under the TCPA.

Disposition

reversed_and_remanded