Third Circuit Continues Trend of Creating Class Certification Hurdles for Mutli-State Class Actions

The Third Circuit recently ruled in Grandalski v. Quest Diagnostics, Inc., that the common law claims in a nationwide class action were not appropriate for class treatment because the court would be required to conduct an individual analysis and application of each state’s law and therefore common questions of law did not predominate. 767 F.3d 175 (3d Cir. 2014).

Background

Plaintiffs in Grandalski, a group of patients, filed a putative class action alleging that Quest Diagnostics, Inc. routinely overbilled patients. Id. at 177. Plaintiffs proposed two nationwide litigation classes and asserted multiple causes of action against both classes including a state law claim for consumer fraud. Id. at 178. Plaintiffs moved for class certification on all its claims for both its nationwide classes. Id.

To read more about this blog, click here.