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Szabo v. Bridgeport Machines, Inc.

    Brief Fact Summary.

    Szabo moved for class certification for anyone who purchased a Bridgeport Machines, Inc. machining center with a defective control panel within a certain period of time and suffered damages.

    Synopsis of Rule of Law.

    A class can be certified under FRCP 23(b)(3) if a class satisfies the requirements of numerosity, commonality, typicality, and adequate representation.

    Facts.

    Szabo, an Indiana resident, purchased a vertical machining center from Bridgeport Machines, Inc. (Bridgeport). Bridgeport is a Delaware corporation with its principal place of business in Connecticut. Szabo claimed that the machine did not comply with Bridgeport’s promotional materials or offer letters. Szabo argued that Bridgeport knew that the machine’s control unit was defective and sued in federal court. Szabo moved for class certification for anyone who purchased a Bridgeport machining center with a defective control panel within a certain period of time and suffered damages.

    Issue.

    Whether a class can be certified under FRCP 23(b)(3) if a class satisfies the requirements of numerosity, commonality, typicality, and adequate representation?

    Held.

    Yes. Certification is proper. Szabo showed that a class action is the best way to handle the case because the class is large, hiring experts would not be cost effective for individual members, and separate suits would remain unsuitable.

    Discussion.

    A class can be certified under FRCP 23(b)(3) if a class satisfies the requirements of numerosity, commonality, typicality, and adequate representation. Numerosity occurs when joinder is impracticable because the class is numerous; commonality occurs when there is law or fact common to all; typicality occurs when the class’s claims and defenses are typical to the classes; and adequate representation is satisfied when the class representative can safeguard the class’s interests. Certification allows class action if common questions of law predominate over questions of individual members, and a class action is the best way to resolve the case.


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