Adams v. Robertson

Background

In 1992 a class-action lawsuit accused an insurance company of pushing customers to swap old policies for new ones that gave less cancer coverage. A trial court in Alabama certified the class under state rules that did not let class members exclude themselves. The court approved a settlement that barred class members from suing the insurer individually. Some class members objected and appealed. The Alabama Supreme Court affirmed on state-law grounds and did not address the federal due process question the objectors later asked this Court to review.

Reasoning

The core question presented here was whether the Constitution’s due process protection requires that class members be allowed to opt out of a class or its settlement when money is at issue. The Justices did not decide that question because the objecting class members failed to show they had properly raised that federal due process claim in the Alabama Supreme Court. The Court explained that when a state high court is silent on a federal issue, the party asking this Court to review must show the state court had a fair chance to consider it. Because the federal claim was not clearly presented and petitioners did not meet state briefing rules, the Court dismissed the writ as improvidently granted instead of ruling on the merits.

Real world impact

This decision leaves the Alabama class certification and the settlement in place for now and gives the State’s highest court the first opportunity to decide whether its rules meet federal due process. The ruling is not a final answer on whether class members must be allowed to opt out; that constitutional question remains open for future proceedings.