Laboratory Corp. of America Holdings v. Davis
The Supreme Court dismissed a case it had agreed to hear — about whether class-action damages lawsuits may sweep in people who were never actually harmed — without deciding the question, leaving the lower court's ruling in place.
The dismissal resolves nothing on the merits: a Ninth Circuit rule allowing large classes that include more than a small number of uninjured members remains intact for now, and a lone dissenting justice argued the Court should have used this case to strike that rule down.
How it got here: A California federal trial court certified a broad damages class; the Ninth Circuit affirmed on interlocutory appeal; Labcorp sought and received Supreme Court review, which the Court then dismissed without deciding anything.
The Case in Depth
What happened
Labcorp, a national medical-testing company, introduced self-service check-in kiosks at its California locations in 2017. Legally blind patients sued, arguing the kiosks were inaccessible and violated the Americans with Disabilities Act and a California anti-discrimination law that awards at least $4,000 per violation. They sought certification of a class of all blind California Labcorp patients, with potential damages reaching roughly $500 million per year. Labcorp argued the class was too broad because it would include blind patients who preferred front-desk service and were never actually denied anything.
The question before the Court
Can a federal court certify a class-action lawsuit for money damages when the class includes people who were not actually harmed by the defendant's conduct?
The Court's answer
No answer — the Court dismissed the case without deciding whether damages class actions may include members who were not harmed. The justices had previously agreed to hear the question, but after briefing and oral argument, a majority declined to proceed. A threshold dispute arose over whether Labcorp had appealed the right court order, raising a question about whether there was anything for the Court to decide. Rather than resolve that dispute or move on to the main class-action question, the Court simply dismissed the case as having been improvidently — meaning mistakenly — accepted in the first place.
The Ninth Circuit's original ruling, which allowed the broad damages class, therefore stands. The Court expressed no view on whether that ruling is correct.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Companies facing class-action lawsuits — particularly in California — remain subject to the Ninth Circuit's rule permitting damages classes that include members who suffered no actual harm. Businesses say this exposes them to massive, coercive settlements; consumer and disability-rights advocates say narrowing class eligibility makes it harder to hold companies accountable for widespread violations affecting large groups.
What changes now
The case returns to the lower courts with the Ninth Circuit's ruling intact, meaning the broad damages class — potentially covering thousands of blind Californians — survives for now and the lawsuit against Labcorp continues. The underlying question of whether damages classes may include uninjured members remains unresolved nationwide. Other circuits that have taken stricter positions on this issue will continue to diverge from the Ninth Circuit until the Supreme Court takes up a suitable vehicle to settle the question.
What this does not decide
The Court did not decide whether damages class actions may include both injured and uninjured members — that question is entirely open. The Court also did not decide whether the case was moot. The dismissal is not an endorsement of the Ninth Circuit's approach; it is simply a refusal to rule either way.
Concurrences and dissents
Dissent — Justice Kavanaugh
“Classes that are overinflated with uninjured members raise the stakes for businesses that are the targets of class actions.”Justice Kavanaugh explaining why overbroad class certification can pressure businesses into costly settlements even when the underlying claims are weak.
Justice Kavanaugh would have reached the merits and ruled that federal courts cannot certify a damages class under Rule 23 when it includes both injured and uninjured members. He argued that Rule 23 requires common questions to predominate, and that requirement cannot be met when some members of the class suffered no injury at all. He also rejected the mootness argument, explaining that Labcorp had no procedural option other than to appeal the order it challenged.
How the Court got there
The legal reasoning, step by step
- The Court gave no reasoning — the entire per curiam opinion is a single sentence dismissing the case as 'improvidently granted,' a term meaning the Court concludes, after full briefing and argument, that it should not have taken the case.
- According to the lone dissent, the most likely explanation is that a majority of the Court did not want to resolve a threshold mootness dispute that arose after the case was accepted: the blind patients argued Labcorp had appealed the wrong class-certification order, which would mean there was no valid appeal before the Court at all.
- The dissent argued this mootness concern was unfounded — Labcorp could only have appealed the May 2022 certification order under Ninth Circuit procedural rules, because the later August 2022 order expressly made no material change and therefore was not itself appealable.
- Because the Court dismissed without reaching the mootness question or the class-action question, the Ninth Circuit's judgment approving the damages class stands by default — not because the Supreme Court endorsed it, but simply because the Court chose not to disturb it.