Amchem Products, Inc. v. Windsor (1996)
- Docket
- 96-270
- Decided
- 1996-01-01
Summary
Question: May settlement play a role, under FRCP 23, in determining the propriety of class certification? Conclusion: Yes, but a limited one. While the court of appeals had erred by stating that settlement was not relevant to class certification determinations, the lower court had, in fact, closely examined the terms of the settlement, and remand was therefore not merited. A court considering a class for settlement need not consider whether certification would present intractable management problems at the trial stage, but the remaining requirements of FRCP 23 must be met. Here those requirements were not fulfilled. First, despite the over-arching issue of asbestos-related health problems, common issues did not predominate given the very different injuries suffered by the plaintiffs, and the fact that some class members had not yet manifested physical disease. FRCP 23(b)(3). Second, the named parties would not adequately represent the class because those currently injured had interests distinct from those who had been exposed to asbestos but had not yet exhibited any physical symptoms. FRCP 23(a)(4). In resolving the case the Court declined to reach the issue of whether the settlement proceeding was a justiciable case or controversy under Article III because, it held, determination of class certification was logically antecedent to these issues.