Class Action Claims Were Moot After Class Representative Settled His Individual Claims

Proskauer - California Employment Law
Contact

Proskauer - California Employment Law

Brady v. AutoZone Stores, 960 F.3d 1172 (9th Cir. 2020)

Michael Brady sued AutoZone Stores for alleged violations of Washington State’s meal break laws. After several years of litigation, the district court denied Brady’s motion for class certification; Brady then settled his individual claims with AutoZone. Although the settlement agreement stated that it was “not intended to settle or resolve Brady’s Class Claims,” it did not provide that Brady would be entitled to any financial reward if the unresolved class claims were ultimately successful. The Ninth Circuit dismissed as moot Brady’s appeal from the district court’s denial of class certification: “A class representative must … retain a financial stake in the outcome of the class claims. Absent such a stake, a class representative’s voluntary settlement of individual claims renders class claims moot.” See also Williams v. U.S. Bancorp Investments, Inc., 50 Cal. App. 5th 111 (2020) (collateral estoppel doctrine does not bar an absent class member in a putative class that was initially certified, but later decertified, from subsequently pursuing an identical class action)

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Proskauer - California Employment Law | Attorney Advertising

Written by:

Proskauer - California Employment Law
Contact
more
less

Proskauer - California Employment Law on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.