Stuart v. State Farm Fire and Casualty Co., No. 16-3784 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed the district court's order certifying a class of Arkansas homeowners who alleged that State Farm improperly withheld amounts for labor depreciation when making payments under their insurance policies. The court held that the district court did not abuse its discretion by concluding that plaintiffs' claims shared a common, predominating question of law. In this case, plaintiffs' theory was that State Farm violated its contractual obligations by depreciating both materials and labor when calculating ACV, thereby reducing the size of their ACV payments.
The court also held that the district court properly noted that the class members' claims were generally small and unlikely to be pursued individually; that concentrating the claims in a single forum was desirable; and that it did not anticipate unreasonable difficulty in managing the class action. The court explained that the fact that some plaintiffs may be unable to succeed on their claims did not necessarily mean that they lack standing to sue. Finally, the court modified the certification order to exclude those subject to another settlement from the class definition.