ST. PAUL, Minn. - Reversing a lower court's certification of a class of North Dakota auto insurance policyholders, an Eighth Circuit U.S. Court of Appeals panel on July 3 held that the predominance requirement of Federal Rule of Civil Procedure 23(b)(3) had not been met (Gale Halvorson, et al. v. Auto-Owners Insurance Co., et al., No. 12-1716, 8th Cir.; 2013 U.S. App. LEXIS 13580).