Supreme Court Dismisses Landmark Class Action Case: What It Means for Consumers

In a notable development for class-action litigation, the U.S. Supreme Court recently dismissed a highly anticipated case, Laboratory Corporation of America Holdings v. Davis. The decision effectively left unresolved a critical issue: whether federal courts can certify classes comprising both injured and uninjured individuals under Federal Rule of Civil Procedure 23.

This dismissal, unusual in its timing and circumstances, underscores the ongoing complexity and controversy surrounding class-action litigation nationwide.

Background of the Case

The case originated from LabCorp’s introduction of touchscreen check-in kiosks in 2017. Plaintiffs argued these kiosks were inaccessible to legally blind individuals, thus violating the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. A district court certified a class consisting of legally blind California residents who encountered barriers due to these kiosks. LabCorp objected, asserting that the class definition was overly broad as it potentially included individuals who had not intended or attempted to use the kiosks, categorizing them as “uninjured” members.

When the Ninth Circuit Court of Appeals upheld the class certification, it relied on precedent allowing classes that included more than a minimal number of potentially uninjured members. This approach, while debated, has enabled broader classes, empowering more plaintiffs to collectively address grievances against powerful corporations.

The Supreme Court’s Dismissal

Initially agreeing to review the case, the Supreme Court was set to determine whether Rule 23 permits certifying classes that include both injured and non-injured individuals. Federal Rule of Civil Procedure 23, which governs federal class actions, mandates commonality, adequacy of representation, and predominance of common questions as prerequisites for class certification.

However, the Court unexpectedly dismissed the writ of certiorari as “improvidently granted,” effectively declining to address this critical legal question after having heard oral arguments. This rare procedural decision signals uncertainty or disagreement among the justices regarding either the substance or procedural viability of the case.

Justice Brett Kavanaugh notably dissented from the dismissal, highlighting the critical nature of the unresolved issue. According to Kavanaugh, the Court’s decision likely reflects reluctance to grapple with a complex mootness argument presented by the plaintiffs, who argued LabCorp’s appeal concerned an outdated class-certification order. Kavanaugh believed this mootness claim lacked substantial merit and that the Court should have directly resolved the issue at hand.

Implications for Class Actions

The dismissal has significant implications. By leaving this fundamental question unresolved, the Court permits lower federal courts to retain flexibility when defining class membership. This flexibility allows broader class definitions, which is essential for plaintiffs seeking to pool resources against well-resourced corporate defendants.

Justice Kavanaugh’s dissent argues that overly broad classes could impose undue financial burdens on businesses. He warned this could lead companies to settle claims, regardless of merit, to avoid unpredictable litigation costs. His concerns reflect a broader debate about balancing the rights of consumers with the need to protect businesses from overly expansive litigation.

Ralph Kalfayan, a respected California class action attorney, provided valuable insights to Law Commentary, a legal news organization, on the ruling. Kalfayan highlighted the Court’s decision to avoid restricting classes exclusively to clearly injured individuals. He stated, “By not explicitly restricting classes, lower courts retain the flexibility to certify broader classes, thereby increasing access to justice for plaintiffs who might otherwise be excluded.”

Kalfayan’s perspective aligns with consumer advocacy, emphasizing that broader class definitions can strengthen collective actions as tools for accountability. He also acknowledged the legitimate concerns raised by Justice Kavanaugh but maintained that an inclusive approach ultimately empowers consumers and enhances corporate accountability.

With this significant question remaining unresolved, lower courts will likely see continued debate and litigation surrounding class certifications. Federal appeals courts across the nation remain divided, indicating that similar issues will undoubtedly reemerge before the Supreme Court.

Contact The Kalfayan Law Firm

If you believe your consumer rights have been compromised and you are considering participating in or initiating a class action, it’s crucial to have experienced legal counsel by your side. The Kalfayan Law Firm specializes in class actions that hold corporations accountable and protect consumer rights.

Contact us today for a consultation and learn how our experienced attorneys can support you in pursuing justice.