Sixth Circuit Vacates Class Certification Order Due To State Court Settlement
In Gooch v. Life Investors Insurance Company of America, Nos. 10–5003, 10–5723, 2012 WL 410926 (6th Cir. Feb. 10, 2012), the Sixth Circuit noted that the district court improperly applied the "clearly wrong" standard in deciding class certification by assuming the class representative's allegations to be true and resolving all doubts “in the plaintiff's favor” while conducting what it called “[a] limited factual inquiry into the class allegations, including the deposition of the named plaintiff.” The court noted this did not comply with the “rigorous analysis” standard, but concluded the error was harmless because the court based its decision on affidavits it deemed sufficient, probed behind the pleadings, and considered all relevant documents in evidence. The court ultimately vacated the class certification order because a state court settlement precluded the claims of most class members
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