Federal law delineates a magistrate judge's exercise of
jurisdiction over a civil case. Specifically, with the
“consent of the parties,” a magistrate judge may
conduct “any or all proceedings . . . and order the entry of
judgement.” 28 U.S.C. § 636(c)(1). Recently,
in McAdams v. Robinson, 26 F.4th 149 (4th Cir. 2022),
the Fourth Circuit determined that the word “parties”
in this statute does not include absent class members.
Consequently, a magistrate judge may conduct proceedings and enter
judgment with the consent of only the named parties.
The case began as a putative consumer class action, when
Demetrius and Tamara Robinson alleged that Nationstar Mortgage LLC
had violated federal and state law by failing to timely process
loss mitigation applications. Six years after the Robinsons filed
their case, the named parties submitted a proposed settlement
agreement seeking court approval of a class settlement and jointly
asked to proceed before a magistrate judge. The
