The United States Court of Appeals for the Fifth Circuit affirmed a district court’s denial of class certification to a group of Louisiana GEICO customers who allege the insurer’s proprietary valuation system violated state law.
Plaintiffs Eric Prudhomme and Elvin Jack failed to show want of commonality, adequacy, and predominance among the proposed class, the district court said.
In rejecting the appellants’ proposed class, the district court questioned whether the appellants’ theory of liability would benefit all members of the class. The Federal Rules of Civil Procedure require that the representative parties in a class-action will “fairly and adequately protect the interests of the class.”
“Indeed, a portion of the proposed class members received payments above (that is, benefitted from) the allegedly unlawful valuation,” summarized Circuit Judges Carolyn Dineen King, Gregg J. Costa and Don R. Willett. “This undermined Appellants’ class-wide theory of liability and thereby doomed adequacy. “
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