Angela M. Schaefer

Angela Schaefer joined the firm’s Huntsville office as an associate in the Appellate Practice Group after clerking for Judge John M. Rogers on the United States Court of Appeals for the Sixth Circuit in Lexington, Kentucky. She graduated from the University of Alabama School of Law, where she was an executive editor of the Alabama Law Review and a member of the American Bar Association National Moot Court Team, as well as the John A. Campbell Moot Court Board. While attending law school, Angela coauthored an article on the Second Amendment, published in the Harvard Journal on Legislation.

Latest Articles

International Trade Law

USTR Initiates Process to Levy Additional Duties on $200 Billion Worth of Chinese Goods

By John Brew, Angela M. Schaefer, Frances P. Hadfield, Spencer Toubia & Edward Goetz

July 11, 2018

On July 10, 2018, U.S. Trade Representative (USTR) Robert Lighthizer announced that at President Trump’s request, USTR has initiated the process of imposing an additional 10 percent ad valorem duty on approximately $200 billion worth of imports from China including apparel, textiles, chemicals, and agricultural & aquacultural goods. The USTR statement includes a link to an advance copy of the Federal Register Notice with the list of proposed tariffs and the process for the public…

International Trade Law

No Section 232 Product Exclusions for Countries Subject to Steel or Aluminum Quotas

By Angela M. Schaefer, Yun Gao, Cherie Walterman & Edward Goetz

June 6, 2018

Media sources are reporting the Department of Commerce will not consider steel and aluminum product exclusions for countries subject to quotas. Only countries facing the tariffs will be considered for product exclusions. Currently, South Korea, Brazil, and Argentina have agreed to an absolute quota deal on certain steel products that are subject to the Section 232 tariffs. The steel quotas are separated into 54 subcategories for South Korea, Argentina, and Brazil. Argentina has already reached…

International Trade Law

President Makes Decisions on Country Exemptions for Section 232 Tariffs

By Daniel Cannistra, Angela M. Schaefer & Cherie Walterman

May 1, 2018

On April 30th, the President issued two proclamations extending country exemptions for certain U.S. allies on the steel and aluminum tariffs pursuant to Section 232(b) of the Trade Expansion Act of 1962. The President extended temporary exemptions for Canada, Mexico, and the European Union, granted a permanent exemption on steel tariffs for South Korea, and is considering permanent exemptions for Australia, Argentina, and Brazil. Trump’s administration unveiled its decision to extend the country exemptions just…

International Trade Law

Safeguard tariffs imposed by U.S. on solar panels and washing machines are first since 2002 steel import restrictions.

By Angela M. Schaefer & Frances P. Hadfield

January 23, 2018

On January 22nd, President Trump imposed new “safeguard” tariffs on imported solar panels and washing machines, which will be in place for the next three years before tapering downward. For the renewable energy industry, this is another major blow from this administration. Solar panels, most of which currently come from China will have an additional tariff rate of 30% imposed. Notably, there are already more than 150 other U.S. trade measures in place against various…

International Trade Law

Commerce Submits its Section 232 Report on Steel Imports to President Trump

By Daniel Cannistra, Angela M. Schaefer, Robert L. LaFrankie & Cherie Walterman

January 12, 2018

The Department of Commerce submitted its report on the impact of steel mill product imports on U.S. national security to President Trump on January 11. In a statement on its website, the Department announced that the long-awaited results of the investigation, commonly known as the Section 232 Report, will not be made public until after the President makes his final decision. Although the president has 90 days to act, he has the discretion to announce his decision early. …

Declassified

Growing Consensus in the Courts of Appeals against Alternative-Citizenship Theory of Diversity under CAFA

By Angela M. Schaefer

November 16, 2017

If a putative class of plaintiffs, all citizens of State A, sues a corporate defendant, which the law considers to be a citizen of State A and State B, in state court, may the defendant remove the case to federal court under the Class Action Fairness Act (CAFA)? Recently, the Sixth Circuit became the third court of appeals to answer “no.” CAFA, 28 U.S.C. § 1332(d), provides for federal jurisdiction over class actions involving at least…

Tennessee Appellate Review

A Corporation May Not Pick and Choose Its Citizenship to Create Diversity under CAFA

By Angela M. Schaefer

November 8, 2017

The Sixth Circuit became the third court of appeals to reject the “alternative citizenship” theory of diversity under the Class Action Fairness Act (CAFA). In Roberts v. Mars Petcare US, Inc., a putative class of Tennessee citizens sued Mars Petcare in Tennessee state court. Mars Petcare removed the case to federal court, relying on diversity jurisdiction under CAFA, 28 U.S.C. § 1332(d), which provides for federal jurisdiction over class actions involving at least 100 class…

Tennessee Appellate Review

Sixth Circuit Clarifies Where to Appeal in a Transferred Case

By Angela M. Schaefer

October 13, 2017

Last month, the Sixth Circuit subtly deepened a circuit split over a significant question of appellate jurisdiction within the federal courts: When a lawsuit begins in one U.S. district court but is transferred to a second district court within another federal circuit before reaching a final judgment, which court of appeals has jurisdiction to review the first district court’s interlocutory decisions? In Kalama v. Matson Navigation Co., Inc., a panel of the Sixth Circuit…

Declassified

Must Class Counsel’s “Proof” that Rule 23 Is Met Satisfy the Rules of Evidence?

By Michael R. Pennington, Scott Burnett Smith & Angela M. Schaefer

October 4, 2017

All class-action practitioners understand the importance of a court’s decision to certify a class—the pivotal point at which a putative class action can transform into a reality, promising vast settlement pressure on the defendant, even over potentially meritless claims. A cert petition filed with the Supreme Court on September 14 in Taylor Farms Pacific v. Pena could impact future class-certification battles. The petition asks the Court to decide whether a district court may rely on…

International Trade Law

Commerce Probes Impact of Steel, Aluminum Imports on National Security

By Angela M. Schaefer, Charles De Jager, Jeffrey I. Snyder, Daniel Cannistra, John Brew, Robert L. LaFrankie & Alan W. H. Gourley

June 8, 2017

STEEL A Federal Register Notice published on April 26 provided additional information to industry on the Department of Commerce’s investigation of steel imports and U.S. national security. For more detail on the April 21 Presidential Memorandum directing the investigation, please see Crowell’s Client Alert. We learned a three-hour public hearing will be held on May 24 at DOC and that interested parties must request to speak by May 17. The requests need to include…

Angela M. Schaefer

USTR Initiates Process to Levy Additional Duties on $200 Billion Worth of Chinese Goods

No Section 232 Product Exclusions for Countries Subject to Steel or Aluminum Quotas

President Makes Decisions on Country Exemptions for Section 232 Tariffs

Safeguard tariffs imposed by U.S. on solar panels and washing machines are first since 2002 steel import restrictions.

Commerce Submits its Section 232 Report on Steel Imports to President Trump

Growing Consensus in the Courts of Appeals against Alternative-Citizenship Theory of Diversity under CAFA

A Corporation May Not Pick and Choose Its Citizenship to Create Diversity under CAFA

Sixth Circuit Clarifies Where to Appeal in a Transferred Case

Must Class Counsel’s “Proof” that Rule 23 Is Met Satisfy the Rules of Evidence?

Commerce Probes Impact of Steel, Aluminum Imports on National Security

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