Robidoux v. Celani

987 F.2d 931 (2d Cir. 1993)

 

RULE:

Fed. R. Civ. P. 23(a) sets forth the requirements for class certification and requires a potential class representative to show: (1) the class is so numerous that joinder of all members is impracticable, (2) there are questions of law or fact common to the class, (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class, and (4) the representative parties will fairly and adequately protect the interests of the class.

FACTS:

Plaintiffs, three recipients of public assistance in Vermont, sought to represent a class of persons whose applications for public assistance had been delayed unlawfully by defendant, the Vermont Department of Social Welfare. The district court refused to certify plaintiffs’ suit as a class action and dismissed it as moot. Plaintiffs appealed. The appellate court vacated the district court's judgment and remanded the case.

ISSUE:

Did the plaintiffs, who sought to represent a class of public assistance applicants whose applications were delayed unlawfully by a state social welfare department, meet all the requirements for class certification?

ANSWER:

Yes.

CONCLUSION:

Plaintiffs had met all the requirements of Fed. R. Civ. P. 23, and the district court abused its discretion in refusing to certify their suit as a class action. Specifically, the district court, in concluding that numerosity was lacking because plaintiffs had not shown the class to be so large that joinder was impossible, applied the wrong standard. Impracticable did not mean impossible. Moreover, plaintiffs' claims met the typicality requirement even if there were minor variations in the fact patterns underlying individual claims.

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