Briseno v. Conagra Foods, Inc.

Brief Fact Summary.

Briseno and other consumers who purchased Defendant’s “100% Natural” Wesson brand cooking oil filed a class action lawsuit alleging that the “100% Natural” label was false or misleading. Defendant Conagra Foods, Inc., manufacturer, marketer, distributer and seller of the “100% Natural” Wesson brand cooking oil product opposed class certification. The district court certified the class and Defendant appealed.

Synopsis of Rule of Law.

Plaintiffs do not have to demonstrate an administratively feasible way to identify class members as a condition for class certification.

Facts.

Plaintiffs, consumers who purchased Defendant’s “100% Natural” Wesson brand cooking oil, alleged that the cooking oil’s “100% Natural” label was false or misleading. Plaintiffs sought to proceed by class action, and sought certification of a class of plaintiffs from various states who purchased the cooking oil within their state’s applicable statute of limitations. Defendant Conagra Foods, Inc., a manufacturer, marketer, distributer and seller of the “100% Natural” Wesson brand cooking oil product, opposed class certification. The district court certified the class and Defendant appealed.

Issue.

Did the district err by not conditioning class certification on Plaintiffs’ providing an administratively feasible way to identify class members.

Held.

No. The district court did not err by not conditioning class certification on Plaintiff’s providing an administratively feasible way to identify class members.

Discussion.

The Court of Appeals for the Ninth Circuit determined that Federal Rule of Civil Procedure did not require, by its language or by implication, that in order for class certification, plaintiffs must demonstrate an administratively feasible way to identify class members.