Summary
The United States Judicial Panel on Multidistrict Litigation orders the transfer of Jones v. AT&T Inc. to the District of Montana for coordinated or consolidated pretrial proceedings in MDL No. 3126, In re Snowflake, Inc., Data Security Breach Litigation. The Panel concludes that the action shares common factual issues with the MDL proceedings and rejects the plaintiff’s objections concerning the AT&T-specific allegations, individualized injuries, class-settlement opt-out, and anticipated delay. The Panel also admonishes the pro se plaintiff for submitting fabricated and misrepresented legal authorities.
Topics
Practice areas
Questions Presented
- Whether the action involved common questions of fact with actions already centralized in MDL No. 3126 so as to warrant transfer under 28 U.S.C. § 1407.
- Whether the action should be excluded from the MDL because it focused exclusively on AT&T, alleged individualized damages, opted out of a class settlement, or would allegedly be delayed by transfer.
- Whether the plaintiff's submission of briefs containing fabricated or misrepresented legal authorities warranted an admonition and potential future corrective action.
Holdings
- The action involves common questions of fact with the actions in MDL No. 3126, and transfer will serve the convenience of the parties and witnesses and promote the just and efficient conduct of the litigation.
- Individualized injuries, opting out of a class settlement, and dissatisfaction with the progress or management of the MDL do not preclude transfer when centralized proceedings otherwise offer substantial efficiencies.
- All litigants, including pro se litigants, have an affirmative duty to conduct a reasonable inquiry into the substance of a filing and to ensure that cited authorities and quotations are real and accurate.
Key quotations
“transfer under 28 U.S.C. § 1407 will serve the convenience of the parties and witnesses and promote the just and efficient conduct of the litigation.” (at 1)
“all litigants (whether represented by counsel or not) are subject to an affirmative duty to conduct a reasonable inquiry into the substance of a filing before they present it to a court.” (at 3)
Factual background
The action concerns alleged breaches of AT&T data stored on the Snowflake cloud platform, including call and text metadata from May 2022 through October 2022 and, for some customers, records from January 2023. The alleged breaches are part of a broader cluster of Snowflake-platform data breaches affecting the personal information of more than 500 million consumers and employees. The plaintiff alleged individualized injuries, including emotional distress and an increased risk of fraud, and sought punitive damages against AT&T.
Procedural history
The action was filed in the Eastern District of California as Jones v. AT&T Inc., C.A. No. 2:25-02952. The Panel denied the motion to vacate and ordered the action transferred to the District of Montana, with that court's consent, for coordinated or consolidated pretrial proceedings before Judge Brian Morris.