Pleadings and Motions

Pleadings

Master Complaint

Master Complaint

Master Complaint

A master complaint states allegations common across cases in an MDL or consolidated proceeding. Individual plaintiffs adopt it by filing a short form complaint identifying case-specific facts.

Whether it supersedes individual pleadings is contested.

Alternative Names:

Consolidated Master Complaint, Master Pleading

Why it Matters?

The supersession question determines what pleading governs after the coordinated proceeding ends, and courts have divided. Where the master complaint is treated as an administrative device, the individual complaints remain operative on remand. Where it supersedes, the operative pleading is one the transferor court never saw. The case management order establishing the structure should address the question rather than leaving it for later dispute.

Frequently asked questions

Does a master complaint supersede individual pleadings?

What should the case management order address?