Laboratory Corp. of America Holdings v. Davis
Headline: Court declines to decide whether a damages class can include injured and uninjured members, dismissing review and leaving a certified class that could expose businesses to large liability and settlements.
Holding: The Court dismissed its review of the case, declined to decide the issue about mixed injured and uninjured damages classes, and thus left the lower-court class-certification ruling in place.
- Leaves the Ninth Circuit’s class-certification ruling in place, so the certified damages class remains effective for now.
- Maintains risk of large statutory damages and potential coercive settlements for businesses facing class suits.
- Raises costs that could be passed on to consumers, retirees, and workers, per the dissent.
Summary
Background
Labcorp is a diagnostic laboratory that introduced touchscreen self-service kiosks in 2017, and legally blind patients sued after saying the kiosks were inaccessible. Plaintiffs relied on the Americans with Disabilities Act and California’s Unruh Civil Rights Act, which provides a $4,000 minimum statutory damage per violation. A District Court certified a statewide damages class in May 2022, later clarified its class definition in August 2022 (saying the change was not material), and the Ninth Circuit ultimately approved the certification after a Rule 23(f) interlocutory appeal. Plaintiffs sought class damages that the parties estimated could be about $500 million per year.
Reasoning
The main question was whether a federal court may certify a damages class that includes both injured and uninjured people. The Supreme Court granted review to answer that question, but the Court dismissed the writ of certiorari as improvidently granted and did not resolve the legal issue. Justice Kavanaugh dissented, arguing the case was not moot and that he would hold such mixed damages classes improper because common questions would not predominate over individual issues.
Real world impact
Because the Court declined to reach the merits, the lower-court class-certification ruling remains in effect for now and the important national question about class composition goes unanswered at the highest level. The dissent warned that allowing overbroad classes can produce massive liability pressure, coerced settlements, and higher costs that get passed on to consumers, retirees, and workers.
Dissents or concurrances
Justice Kavanaugh would have decided the case on the merits, reversed the Ninth Circuit, and held that Rule 23 does not allow damages classes that include both injured and uninjured members because common issues would not predominate.
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