Cullen v. State Farm Mut. Auto. Ins. Co.Annotate this Case
Michael Cullen sued State Farm Mutual Automobile Insurance Company requesting class certification and a declaratory judgment that State Farm failed to disclose all benefits available to policyholders who made claims for damaged windshields. The trial court certified the class, concluding that Cullen and the class satisfied the requirements of Ohio R. Civ. P. 23. The court of appeals affirmed the order certifying the class but reversed the portion of the decision defining the class and remanded with instructions to the trial court to redefine it. The Supreme Court reversed, holding (1) because the declaratory relief at issue here was incidental to an individualized claim for monetary damages, Cullen failed to meet the requirement for certification set forth in Rule 23(B)(2); and (2) Cullen failed to prove that this action satisfied Rule 23(B)(3) because individual questions predominated over the questions common to the proposed class. Remanded.