Johannessohn v. Polaris Industries Inc., No. 20-2347 (8th Cir. 2021)
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Plaintiffs filed a putative class action alleging that Polaris failed to disclose heat defects and that this artificially inflated the price of their all-terrain vehicles. The Eighth Circuit affirmed the district court's denial of class certification, concluding that there was no error in determining that individualized questions predominated, a class action was not a superior method for litigating, and the putative class included members who lacked standing.
In this case, plaintiffs' nationwide class action complaint alleges violations of the the Minnesota Consumer Fraud Act and thus rebuttal evidence is permitted; Polaris has evidence challenging how much each consumer-plaintiff relied on the alleged omissions; and this will require individualized findings on reliance and is likely to make for multiple mini-trials within the class action. The court also explained that, because the class has not been defined in such a way that anyone within it would have standing, the class cannot be certified.
Court Description: [Kobes, Author, with Kelly, and Grasz, Circuit Judges] Civil case - Class Actions. The putative class alleged defendant failed to disclose heat defects and that this artificially inflated the price of their all-terrain vehicles. The district court denied the request for class certification and plaintiffs appeal. Held: The district court did not err in determining that individualized questions predominated, that a class action was not a superior method for litigating, and that the putative class included members who lacked standing. Judge Kelly, concurring in the judgment.
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