252) The Court went on to consider whether the case fell within any traditional equitable head of jurisdiction: irreparable injury, multiplicity of suits, and cloud upon real estate title.
284) Farm processors sought injunctive relief en masse, and the vast majority of federal district courts found equitable grounds, such as multiplicity of suits, sufficient to avoid application of the AIA.
Although courts often recited that any "head of equity jurisdiction"--fraud, mistake, and accident, for example--would suffice to bring the case within equity's purview, (330) the three grounds most often recognized by courts sitting in equity to enjoin taxation were irreparable mischief, multiplicity of suits, and cloud on real estate title.
405, 414 (1896) (noting an exception for "additional special circumstances, bringing the case under some recognized head of equity jurisdiction, such as irreparable injury, multiplicity of suits, or cloud on the title of the complainant"); Frayser v.
It must appear that the enforcement of the tax would lead to a multiplicity of suits, or produce irreparable injury, or where the property is real estate, [and would] throw a cloud upon the title.
79) Second, disallowing an action based on a difference in degree prevents a multiplicity of suits.
85) The rule derives from a need to address traditional standing considerations, such as multiplicity of suits and lack of concrete adversity.
Justification for the special injury rule based on the desire to prevent a multiplicity of suits is also questionable in today's legal structure.
104) Once a class has been properly certified,(105) and all potential members of the class have been provided notice, the fear of a multiplicity of suits greatly diminishes.
1942): "[the purpose of a `class suit' is to save the multiplicity of suits, to reduce the expense of litigation, to make legal procedure more effective and expeditious, and to make available a remedy that would not otherwise exist.
The very purpose of a class suit is to save a multiplicity of suits, to reduce the expense of litigation, to make legal processes more effective and expeditious, and to make available a remedy that would not otherwise exist.