Amit Rana and Antonia Stabile published “Supreme Court Grants Certiorari on Important Class Certification Standards” in the Daily Journal on March 4. The following is an excerpt:
The United States Supreme Court has granted certiorari in Laboratory Corporation of America Holdings v. Davis. The case raises a pivotal question: Can a federal court certify a Rule 23(b)(3) damages class when some proposed class members lack Article III standing? The answer will undoubtedly influence litigation strategies in damages class actions.
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The Background: A Brewing Circuit Split
In 2021, the Supreme Court confirmed that "Article III does not give federal courts the power to order relief to any uninjured plaintiff, class action or not." TransUnion LLC v. Ramirez, 594 U.S. 413, 431 (2021). The TransUnion court was clear that in the class action context, "every class member must have Article III standing in order to recover individual damages." Id. But TransUnion was decided following a final judgment long after the certification stage. Accordingly, courts have grappled with how its holding might influence the predominance inquiry at class certification, creating fertile ground for conflicting rulings.
Click here for the article.