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Keywords

plaintiffdamagesappealcivil procedure
plaintiffdamagesappealcivil procedure

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Harnish v. Widener University School of Law, 833 F.3d 298, 95 Fed.R.Serv.3d 821, 335 Ed. Law Rep. 107

Facts

The plaintiffs, graduates of Widener University School of Law from 2008 to 2011, claimed that the school published misleading statistics about graduate employment rates, stating that 90-97% of graduates were employed, while the actual rate for full-time legal positions was only 50-70%. They alleged that this misrepresentation allowed Widener to charge inflated tuition. The plaintiffs sought class certification for all individuals who enrolled and were charged tuition during the relevant period, arguing that they suffered damages due to the misleading statistics.

The plaintiffs, graduates of Widener University School of Law from 2008 to 2011, claimed that the school published misleading statistics about graduate employment rates, stating that 90-97% of graduates were employed, while the actual rate for full-time legal positions was only 50-70%. They alleged that this misrepresentation allowed Widener to charge inflated tuition.

Issue

Did the proposed class meet the predominance requirement for class certification under Rule 23(b)(3) of the Federal Rules of Civil Procedure?

Did the proposed class meet the predominance requirement for class certification under Rule 23(b)(3) of the Federal Rules of Civil Procedure?

Rule

Under Rule 23(b)(3), a class can be certified only if common questions of law or fact predominate over individual questions, and the named plaintiffs' claims must be typical of the claims of the proposed class.

Under Rule 23(b)(3), a class can be certified only if common questions of law or fact predominate over individual questions, and the named plaintiffs' claims must be typical of the claims of the proposed class.

Analysis

The court analyzed whether the plaintiffs' proposed class-wide evidence was sufficient to demonstrate that all class members suffered damages as a result of Widener's actions. It found that the plaintiffs' theory of inflated tuition was not adequately supported by class-wide evidence, as individual employment outcomes varied significantly among class members. The court concluded that the plaintiffs failed to establish that common questions would predominate over individual inquiries regarding damages.

The court analyzed whether the plaintiffs' proposed class-wide evidence was sufficient to demonstrate that all class members suffered damages as a result of Widener's actions. It found that the plaintiffs' theory of inflated tuition was not adequately supported by class-wide evidence, as individual employment outcomes varied significantly among class members.

Conclusion

The Court of Appeals affirmed the District Court's denial of class certification, concluding that the plaintiffs did not meet the predominance requirement under Rule 23(b)(3).

The Court of Appeals affirmed the District Court's denial of class certification, concluding that the plaintiffs did not meet the predominance requirement under Rule 23(b)(3).

Who won?

Widener University School of Law prevailed in the case because the court found that the plaintiffs failed to provide sufficient evidence to support their claims for class certification.

Widener University School of Law prevailed in the case because the court found that the plaintiffs failed to provide sufficient evidence to support their claims for class certification.

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