Postawko v. Missouri Department of Corrections, No. 17-3029 (8th Cir. 2018)
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Plaintiffs sought class certification for their claims alleging that the MDOC and other related defendants violated the Eighth Amendment and Title II of the Americans with Disabilities Act (ADA) by providing inadequate medical screening and care for chronic Hepatitis C (HCV) viral infections. Plaintiffs alleged that the MDOC's policies exposed the class to a substantial risk of serious harm.
The Eighth Circuit affirmed the district court's grant of class certification, holding that the evidence was sufficient to permit the district court to conduct a rigorous analysis into class certification; the numerosity, commonality, and typicality requirements were met in light of the prospective injunctive and declaratory relief sought; and sufficient evidence of a common policy existed to comply with Rule 23(b)(2). Finally, the court noted that federalism concerns could be considered after the district court imposed an equitable remedy if applicable, and ADA-reated arguments did not relate to the class certification.
Court Description: Erickson, Author, with Wollman and Kelly, Circuit Judges] Civil Case - class certification. District court's grant of class certification on claims the Missouri Department of Corrections and others violated the Eighth Amendment and Title II of the Americans with Disabilities Act by providing inadequate medical screening and care for chronic Hepatitis C viral (HCV) infections is affirmed. The evidence submitted by both parties was sufficient to permit the district court to conduct a rigorous analysis into class certification. The district court did not abuse its discretion in concluding the numerosity, commonality, and typicality requirements were met in light of the prospective injunctive and declaratory relief sought and in holding sufficient evidence of a common policy existed to comply with Rule 23(b)(2). Federalism concerns may be considered after the district court imposes an equitable remedy, if applicable. ADA-related arguments do not relate to the class certification decision.
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