The Supreme Court is currently deliberating on a case, Laboratory Corporation of America Holdings v. Davis, that delves into class certification issues and the definition of injury among class members. This ongoing case discusses whether a district court is authorized to certify a class action inclusive of individuals who have not experienced any recognized injury. Specifically, this arises from a lawsuit initiated by a group of blind individuals against Labcorp for the installation of automated check-in kiosks, purportedly discriminative against the blind.
The case has turned into a procedural quagmire due to Labcorp’s appeal limitation. They only disputed the initial class definition confined to those claiming injury, while the court refined this to encompass anyone visiting the clinic, regardless of their interaction with the kiosks. The U.S. Court of Appeals for the 9th Circuit concluded it lacked jurisdiction to evaluate the second definition due to Labcorp’s oversight in appeal, bringing the Supreme Court into the discussion.
Judicial debates during oral arguments have notably been about the appropriate procedure the court should undertake. Justices Amy Coney Barrett and Sonia Sotomayor emphasized the necessity of remanding the matter to lower courts for a reinvestigation of the second class definition’s challengeability. Other justices, like Elena Kagan and Neil Gorsuch, questioned Labcorp’s argument on a shared injury being requisite for class membership, suggesting that class definitions can evolve and the courts must eventually segregate those truly injured when deciding damages.
The solicitor general’s premise, asserting the necessity of shared injury among all class members due to commonality requirements, was met with strong dissent from Justices Gorsuch and Kagan. The discussions highlighted longstanding practices in class actions that allow for some variance in individual circumstances among class members, provided there is an overarching common question predominating the case.
Despite some expressed concern by Chief Justice John Roberts and Justice Brett Kavanaugh over the potential pressure class certification places on defendants to settle, a tangible route to addressing these procedural nuances seemed elusive. With skepticism from multiple justices regarding their ability to reach a definitive position on the issues at hand, the proceedings indicate a possible inclination towards not intervening but rather redirecting the case for further clarification in lower courts, which suggests a procedural instead of substantive resolution at the Supreme Court level.
For more details on the legal proceedings and opinions surrounding this case, further insights can be found in the SCOTUSblog post.