Class Action Settlement Reached after District Court Denied Motion for Class Action Treatment Precluded Settling Plaintiffs from Appealing Denial of Class Action Motion Eighth Circuit Holds
Plaintiffs, retirees of Case Corporation, filed a putative class action against administrators of the company’s pension and retirement plans for “violat[ing] the terms of the retirees’ pension plan by failing to make certain payments the month after each retiree turned 62 years old. Anderson v. CNH U.S. Pension Plan, 515 F.3d 823 (5th Cir. 2008) [Slip Opn., at 1-3]. In response to the class action complaint, defendants “conceded that they had mistakenly violated [the Plans], and agreed to tender the missed payment (plus interest) to both the named and unnamed members of the putative class.” Id., at 3-4. Plaintiffs filed a motion for certification of the litigation as a class action; simultaneously, the parties were negotiating a potential settlement of the class action claims. Id. By the time the district court ruled on the class action certification motion, defendants had made a substantial portion of the supplemental payments required and had expressed an intention to tender the remaining payments. Id., at 4. The district court denied class certification finding it “unnecessary and inappropriate at this time.” Id. The parties soon thereafter reached a settlement, and plaintiffs then appealed the district court order denying their class action certification motion. Id., at 5. The Eighth Circuit dismissed the appeal as moot.
The Circuit Court held that it did not have jurisdiction over the appeal because there was no Article III case or controversy: Once plaintiffs settled the underlying class action, their claims became moot as they no longer had “a legally cognizable interest in the outcome” of the case. Anderson, at 5 (citing U.S. Parole Comm’n v. Geraghty, 445 U.S. 388, 396 (1980)).