Ruppert v. Principal Life Ins. Co., No. 11-2554 (8th Cir. 2013)
Annotate this CasePlaintiff, as trustee of the Plan, brought this action against Principal, alleging violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. At issue was whether the district court abused its discretion in refusing to certify a class. The court held that the Confidential Agreement and consent judgment in this case permitted plaintiff to revive his individual claim in order to petition the district court for additional recovery and therefore, the district court's decision was not final. Further, plaintiff's voluntary dismissal of his individual claims rendered the case moot where plaintiff has relinquished his claims and there was no longer an Article III case or controversy. Accordingly, the court lacked jurisdiction and dismissed the appeal.
Court Description: Civil case - ERISA. The confidential settlement agreement and consent judgment in this case permit plaintiff to revive his individual claim in order to petition the district court for additional recovery, and the decision is not final for purposes of appeal; assuming there is a final decision, the case is moot because when a putative class plaintiff voluntarily dismisses the individual claims underlying a request for class certification, there is no longer a self-interested party advocating for class treatment in the manner necessary to satisfy Article III standing requirements.
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