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Keywords

plaintiffdefendantdamageslitigationnegligenceliabilityappealclass actionstrict liabilitypunitive damagescompensatory damagescivil procedureappellant
defendantdamageslitigationappealclass actionpunitive damagescompensatory damagescivil procedureappellant

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In re School Asbestos Litigation, 789 F.2d 996, 54 USLW 2579, 4 Fed.R.Serv.3d 750, 32 Ed. Law Rep. 50

Facts

The litigation began with class action complaints filed by several Pennsylvania school districts and the Barnwell, South Carolina School District in the Eastern District of Pennsylvania. The cases were consolidated, and the defendants included approximately fifty entities associated with the asbestos industry. The plaintiffs sought compensatory and punitive damages due to the presence of asbestos in schools, which they were required to test for under federal legislation. The claims were based on various legal theories, including negligence and strict liability.

The litigation began with class action complaints filed by several Pennsylvania school districts and the Barnwell, South Carolina School District in the Eastern District of Pennsylvania. The cases were consolidated, and the defendants included approximately fifty entities associated with the asbestos industry.

Issue

Did the district court abuse its discretion in certifying a nationwide mandatory class for punitive damages and in denying a class certification under Rule 23(b)(2) for injunctive relief?

Did the district court abuse its discretion in certifying a nationwide mandatory class for punitive damages and in denying a class certification under Rule 23(b)(2) for injunctive relief?

Rule

The court applied Federal Rule of Civil Procedure 23, specifically sections (b)(1)(B) for mandatory classes and (b)(3) for opt-out classes, to determine the appropriateness of class certification.

The court applied Federal Rule of Civil Procedure 23, specifically sections (b)(1)(B) for mandatory classes and (b)(3) for opt-out classes, to determine the appropriateness of class certification.

Analysis

The court found that the district court's certification of a mandatory class for punitive damages was not supported by adequate findings and was under-inclusive, as it did not include all potential claimants. The court emphasized that the mandatory class could not achieve its intended objectives and that the claims for injunctive relief were essentially claims for money damages, which could not be maintained as a class action. However, the court affirmed the certification of the opt-out class for compensatory damages, noting that common issues existed among the claims.

The court found that the district court's certification of a mandatory class for punitive damages was not supported by adequate findings and was under-inclusive, as it did not include all potential claimants.

Conclusion

The Court of Appeals affirmed the certification of the opt-out class for compensatory damages but vacated the certification of the mandatory class for punitive damages, concluding that the district court had abused its discretion.

The Court of Appeals affirmed the certification of the opt-out class for compensatory damages but vacated the certification of the mandatory class for punitive damages, concluding that the district court had abused its discretion.

Who won?

The prevailing party was the appellants challenging the mandatory class certification, as the Court of Appeals found that the district court had abused its discretion in that regard.

The prevailing party was the appellants challenging the mandatory class certification, as the Court of Appeals found that the district court had abused its discretion in that regard.

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