Amchem Products, Inc. v. Windsor

Brief Fact Summary.

Plaintiffs and Defendant attempt to create a class for settlement purposes.

Synopsis of Rule of Law.

A court considering class certification for the purpose of settlement does not need to determine whether certification would create significant problems at the trial stage, but must ensure that the requirements of FRCP 23 are satisfied.

Facts.

A series of asbestos claims were transferred to the Federal District Court for the Eastern District of Pennsylvania. After consolidation parties reached a global partial settlement. The settlement attempted to certify all people with potential asbestos claims that had not yet filed suit to be certified pursuant to FRCP 23(b)(3) for settlement purposes. The settlement was intended to create a fund for certain asbestos diseases. The district court approved the settlement and certified the class. On appeal the Court of Appeals for the Third Circuit reversed the lower court’s approval of the settlement finding that class certification was not satisfied, and that while class certification for the purpose of settlement is allowed, the requirement of FRCP 23 must still be met. The appellate court found error with this certification because the class failed to demonstrate that common issues of fact predominated over other questions as required by FRCP 23(b)(3) and that the named class representatives would adequately represent the class. Windsor petitioned the Supreme Court which granted certiorari.

Issue.

Does the class certification of a class that occurs for the sole purpose of settlement under FRCP 23 affect whether class certification is correct?

Held.

Yes, the class certification of a class that occurs for the sole purpose of settlement under FRCP 23 does affect whether class certification is correct, but it is only minorly important. The decision of the court of appeals is upheld.

Dissent.

Justice Justice Breyer with Justice Stevens concurring in part and dissenting in part

The majority’s holding that class certification solely for settlement is partly relevant to class certification is appropriate, but their approach would lead to a different result.

Concurrence.

Justice Justice Breyer with Justice Stevens concurring in part and dissenting in part

The majority’s holding that class certification solely for settlement is partly relevant to class certification is appropriate, but their approach would lead to a different result.

Discussion.

1. While a court only needs to consider whether certification would present problems at the trial stage for classes certified for the purpose of settlement, the other requirements of FRCP 23 must still be met.
2. These requirements were not met in this case because common issues do not predominate given the varying injuries suffered, which is exacerbated by the fact that some class members‘ have not yet developed diseases. This means that the class does not meet the requirements of FRCP 23(b)(3).
3. Also, the class representatives do not adequately represent the class because they are currently injured and their interests differ from those class members that have not yet started exhibiting symptoms.
4. The court does not address the issue of justiciability under the Constitution because the class certification is the preliminary issue.
5. While the court of appeals incorrectly found that settlement did not have a bearing on class certification, it is harmless because the lower court looked at the issue closely.
6. The decision of the court of appeals is upheld.