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List of Forms by Chapter - Chapter 1 — Historical Perspective
- I. [1.1] Scope of Chapter
- II. [1.2] English Equity Origins
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III. Early Class Action Practice in the United States - IV. [1.6] Original Federal Rule of Civil Procedure 23
- V. Federal Rule of Civil Procedure 23 as Revised in 1966 and Subsequent Amendments
- VI. [1.14] Federal Legislative Developments Affecting Class Action Practice
- VII. [1.18] History of Illinois Class Action Law
- Chapter 2 — Rule 23 Purposes and Prerequisites
- I. [2.1] Scope of Chapter
- II. [2.2] Purposes of Federal Rule of Civil Procedure 23
- III. [2.7] Prerequisites to Maintaining Class Action Under Federal Rule of Civil Procedure 23
- Requirements of Federal Rules of Civil Procedure 23(a) and 23(b) in General
- [2.8] Scheme of Federal Rules of Civil Procedure 23(a) and 23(b)
- [2.9] Federal Rule of Civil Procedure 23(a) — General Requirements
- [2.10] Federal Rule of Civil Procedure 23(b) — General Requirements
- [2.11] Overlapping Requirements of Federal Rules of Civil Procedure 23(a) and 23(b)
- [2.12] Burden of Establishing That Class Action Prerequisites Have Been Met
- Prerequisites Under Federal Rule of Civil Procedure 23(a)
- [2.13] Explicit and Implict Requirements of Federal Rule of Civil Procedure 23(a)
- [2.14] Class Certification Hearing
- [2.15] Defining the Class — The Implicit Ascertainability Requirement
- Federal Rule of Civil Procedure 23(a) Requirements
- [2.16] Numerosity
- [2.17] Burden of showing numerosity
- [2.18] Other factors making joinder impracticable
- [2.19] Judicial economy
- [2.20] Geographic dispersion
- [2.21] Financial resources
- [2.22] Ability to file individual suits
- [2.23] Effect on future class members
- [2.24] Other factors
- [2.25] Size of class
- [2.26] Numerosity not satisfied
- [2.27] Numerosity satisfied
- [2.28] Common Questions of Law and Fact
- [2.29] Typicality
- Adequacy of Representation
- [2.30] Requirement in general
- Adequacy of the representative party
- [2.31] Is the representative party a member of the class?
- [2.32] Do the interests of the representative party coincide with the interests of the class?
- [2.33] Does the representative party’s relationship to his or her attorney indicate that the party is more interested in recovering attorneys’ fees than in obtaining relief for the class?
- [2.34] Can the representative party afford to pay for the cost of litigation, including the cost of notice to the class?
- [2.35] Do personal characteristics of the plaintiffs render them inadequate representatives?
- [2.36] Adequacy of the attorney for the class
- Is the attorney for the class legally qualified to represent the class?
- [2.37] Federal Rule of Civil Procedure 23(g): appointment of counsel
- [2.38] Criteria applied for determining the adequacy of class counsel
- Does the attorney for the class meet the requisite ethical standards for representing the class?
- [2.39] Potential for abuse of Federal Rule of Civil Procedure 23
- [2.40] Solicitation of class members
- [2.41] Improper communications with class members
- [2.42] Collusive settlements
- Article III (Case or Controversy) Standing
- [2.43] Requirement of Standing
- [2.44] Mootness
- [2.45] Prerequisites Under Federal Rule of Civil Procedure 23(b)
- [2.46] Federal Rule of Civil Procedure 23(b)(1) Class Actions
- [2.47] Federal Rule of Civil Procedure 23(b)(1)(A)
- [2.48] Does Federal Rule of Civil Procedure 23(b)(1)(A) apply to actions for damages?
- [2.49] Does Federal Rule of Civil Procedure 23(b)(1)(A) apply to medical monitoring claims?
- [2.50] Can the party opposing a class action waive application of Federal Rule of Civil Procedure 23(b)(1)(A)?
- [2.51] Federal Rule of Civil Procedure 23(b)(1)(B)
- [2.52] Does Federal Rule of Civil Procedure 23(b)(1)(B) apply to actions for damages?
- [2.53] Does Federal Rule of Civil Procedure 23(b)(1)(B) apply when a decision in an individual action might be applied as precedent?
- [2.54] Federal Rule of Civil Procedure 23(b)(2) Class Actions
- [2.55] Action by Party Opposing the Class with Respect to the Class
- [2.56] Injunction or Corresponding Declaratory Relief Appropriate
- [2.57] Predominance of Common Issues Inquiry
- [2.58] Federal Rule of Civil Procedure 23(b)(3) Class Actions
- [2.59] Predominance of Common Questions
- [2.60] Defining “common” and “individual” questions
- [2.61] Determining predominance
- [2.62] Predominance of damage issues
- [2.63] Individualized defenses and uninjured class members
- [2.64] Predominance in fraud cases
- [2.65] Superiority
- Factors relating to superiority determination
- [2.66] “Other” factors
- [2.67] Class members’ interest in controlling litigation
- [2.68] Pending litigation
- [2.69] Desirability of concentrating litigation in a particular forum
- [2.70] Difficulties in management of class action
- [2.71] Available alternatives to class actions
- [2.72] Purposes of Federal Rule of Civil Procedure 23(b)(3) class actions — convenience and desirability
- [2.73] Convenience to class members asserting claims
- [2.74] Convenience to parties opposing class
- [2.75] Convenience to courts
- IV. [2.76] Class Certification Appeals Under Federal Rule of Civil Procedure 23(f)
- Chapter 3 — Investigation and Development of Class Cases
- I. [3.1] Introduction
- II. [3.2] Essentials of Class Actions
- [3.3] Finding and Developing Cases
- [3.4] Abundance of Class Action Opportunities
- [3.5] Provability of the Claim
- [3.6] Prefiling Discovery
- [3.7] A Short History of Class Actions from 1853 to the Early 21st Century
- [3.8] 2003 – 2009 Amendments of Federal Rule of Civil Procedure 23
- [3.9] The Federal Class Action Fairness Act of 2005
- III. Fundamental Concepts
- [3.10] In Concept, One Person Sues for Himself or Herself and for Others Similarly Situated
- [3.11] Thereafter, the Court Determines Whether the Case May Be Certified To So Proceed for the Class as Well
- [3.12] Sources of Legal Authority
- [3.13] Prefiling Preparation
- A Good Claim
- [3.14] A Claim That Can Succeed for a Plaintiff
- [3.15] A Claim That Is Replicable for a Class
- [3.16] A Way To Get Paid
- [3.17] A Good Lawyer
- [3.18] Financial Burden
- [3.19] Physical Burden
- [3.20] Experience Factor
- [3.21] Need for Assistance or Referral
- [3.22] Attorneys’ Incentives
- [3.23] A Good Client/Named Plaintiff/Class Representative
- [3.24] A Good Defendant — Preferably One with Substantial Resources
- [3.25] A Good Judge
- [3.26] Some Disincentives and Downside Risks
- IV. Procedural Nuts and Bolts
- [3.27] Where To File — Choosing and Keeping the Case in a Favorable Forum
- Jurisdiction Issues
- [3.28] Exclusive Jurisdiction
- [3.29] Concurrent Jurisdiction
- [3.30] Keeping the Case in the “Launch” Forum
- [3.31] Diversity Jurisdiction
- [3.32] Venue
- [3.33] Class Actions in Federal Court vs. State Court — What They Share
- [3.34] Pleading Claims in Federal Courts: Twombly and Iqbal
- [3.35] The Legal Construct and the Hurdles That Must Be Met
- [3.36] Federal Cases: Federal Rule of Civil Procedure 23(a) Prerequisites and Federal Rule of Civil Procedure 23(b) Categories
- [3.37] Pleading State Claims in Federal Court: Federal and State Class Certification Differences
- [3.38] Miscellaneous Pleading Issues
- [3.39] Federal Pleading — Preemption
- [3.40] Illinois Cases: Prerequisites and Suitability Under §2-801 of the Code of Civil Procedure
- The Importance of Defining the Class by Objective Standards
- [3.41] Ascertainability at Class Certification Stage
- [3.42] Supporting Class Certification Elements by Use of Statistical Surveys
- The Prerequisites
- [3.43] Numerosity
- [3.44] Commonality
- [3.45] Typicality
- Adequate Representation
- [3.46] Plaintiffs have appropriate un-conflicted interest and are represented by qualified counsel
- Adequacy of class representative
- [3.47] Skeletons in the closet
- [3.48] Client finances
- [3.49] What can the class representative get?
- [3.50] Documenting the contingent-fee agreement
- [3.51] Relationship between the class representative and the attorney
- [3.52] Difference between standing and adequacy
- Satisfying Federal Rule of Civil Procedure 23(b)’s Categories or Illinois’ Appropriateness Test
- [3.53] Federal Rule of Civil Procedure 23(b)’s Categories
- [3.54] Illinois’ Appropriateness Test
- [3.55] The Court’s Class Certification Order
- [3.56] Class Certification Need Not Be for Every Issue in the Case
- [3.57] What Class To Certify? Nationwide vs. Single-State Classes
- [3.58] Application of State Law
- [3.59] Strategy: Selecting the Largest Manageable Class
- V. Potential Substantive Claims
- An Incomplete List of Ideas for Cases and Substantive Considerations
- Consumer Fraud Claims
- [3.60] Basic Concepts
- [3.61] Consumer Fraud Case Developments
- [3.62] Resolution from the Illinois Supreme Court
- [3.63] Unfairness as Actionable All by Itself, Without Deception
- [3.64] Antitrust Claims for Consumers
- [3.65] Employment Claims
- [3.66] Whistleblowers — Under Federal and State Law
- [3.67] Civil Racketeer Influenced and Corrupt Organizations Act
- [3.68] Vehicle Repossession Practices
- [3.69] Healthcare Charges
- [3.70] Healthcare Subrogation/Reimbursement Liens
- [3.71] Excessive or Unreasonable Charges for Copies of Medical Records
- [3.72] Insurance
- [3.73] Judicial Salaries
- [3.74] Junk Faxes
- [3.75] Personal Injury Claims
- [3.76] Civil Rights Acts
- [3.77] Car Defects
- [3.78] Real Estate Investment Frauds
- [3.79] Commodities Frauds and Bogus Charges
- [3.80] Subrogation/Lien Practices of Insurance Companies
- [3.81] Debt Collection, Repossession, and Sale Practices
- [3.82] Shareholder/Securities Fraud Claims; Securities Cases in Other Forms
- [3.83] Challenges to Taxes
- [3.84] Asserting Class Claim as a Counterattack
- [3.85] Inmate/Prisoner Actions
- [3.86] Challenges to Medicaid/Medicare Provisions
- [3.87] Privacy Actions; Digital Breach Cases
- [3.88] Holocaust Asset Recoveries, Alien Tort Claims Act, State-Sponsored Terrorism Exception to Foreign Sovereign Immunities Act
- [3.89] Mortgages — Collection and Modification Abuse, Home Affordable Mortgage Program, and Mortgage Modification Abuse
- [3.90] COVID-19/Coronavirus Pandemic Cases
- [3.91] Other Ways To Bring a Class-Type Claim
- [3.92] Derivative Claims
- [3.93] Corporate Context
- [3.94] Taxpayer Context
- [3.95] Employee Stock Ownership Plan and Trust Litigation
- [3.96] Defendant Class Actions
- [3.97] Qui Tam, False Claims, Citizen Suits, and Whistleblower Cases
- VI. [3.98] Showstoppers and Other Traps for the Unwary
- [3.99] Illinois Insurance Code
- [3.100] Parallel Proceedings
- [3.101] Beware of Prospective Claims
- [3.102] Pre-Certification Tenders — The Threat of Involuntary Mootness
- [3.103] The “Voluntary Payment” Doctrine
- [3.104] Fuzzy Memories Fatal to the Claim
- [3.105] Regulatory Exemptions to Consumer Fraud Claims
- [3.106] First Bite Free
- [3.107] Arbitration Clauses and Class Claims in Arbitration
- [3.108] The Role of Objector to Class Action Settlements
- VII. Unique Class Action Challenges and Issues To Consider
- VIII. Class Certifiability in Various Types of Cases Requiring Ability To Identify at Certification Stage
- [3.113] Challenges to Governmental Actions
- [3.114] Utilities Cases
- [3.115] Statutes of Limitations/Repose
- [3.116] Fluid Recovery Class as a Means To Effect Justice for Unknown Purchasers
- [3.117] Settlement Approvals and Fees
- [3.118] Cy Pres Settlements and Remainder Contributions
- [3.119] Coupon Settlements
- [3.120] Defendant Class Actions
- [3.121] An Incomplete List of Other Class Cases and Possible Actions
- IX. [3.122] Conclusion
- Chapter 4 — Discovery
- I. [4.1] Scope of Chapter
- II. [4.2] Know the Rules Before Getting Started
- III. Plan for Discovery: What Is Needed; When It Is Needed; and How It Will Be Preserved and Managed
- [4.6] Discovery Plan
- [4.7] The Class Action Fairness Act of 2005 and Early Case Discovery
- [4.8] Investigation and Collection of Information
- [4.9] Technology and Electronic Discovery Considerations
- [4.10] Overview of the Federal Rules Regarding Electronic Discovery
- [4.11] Federal Rule of Civil Procedure 34: Production includes electronically stored information
- [4.12] Federal Rules of Civil Procedure 16(b), 26(a), and 26(f): Initial disclosures and scheduling must consider electronically stored information
- [4.13] Federal Rule of Civil Procedure 26(b)(2): Limitations on electronically stored information discovery
- [4.14] Federal Rules of Civil Procedure 37(e), 37(f): Sanctions
- [4.15] Overview of Enacted Illinois Supreme Court Rules Regarding Electronically Stored Information
- [4.16] Illinois Supreme Court Rules 201 and 204: Scope of discovery and proportionality
- [4.17] Illinois Supreme Court Rule 214: Discovery of documents, objects, and tangible things
- [4.18] Illinois Supreme Court Rule 219: Consequences of refusal to comply with rules
- [4.19] Electronic Discovery Planning
- [4.20] Planning with the client
- [4.21] Planning with opposing counsel — the importance of cooperation and transparency
- [4.22] Searching electronic documents and “predictive coding” innovations
- [4.23] Metadata
- [4.24] Cost shifting
- [4.25] Privilege issues: The danger of inconsistent review
- [4.26] Software and Vendors
- [4.27] Retention and Preservation Issues
- [4.28] Preservation Order
- [4.29] Litigation Holds and Consequences
- [4.30] Spoliation and Sanctions
- [4.31] Remedies
- [4.32] Notice to Corporate Clients Regarding Document Retention When Served with Class Action Complaint
- [4.33] Discovery Management
- [4.34] Court’s Case Management Orders: Include Discovery
- [4.35] Protective Orders
- [4.36] Protecting and Retrieving Confidential Information
- [4.37] Bifurcation of Discovery: Limiting Discovery Prior to Certification Ruling
- [4.38] Discovery Impact of the United States Supreme Court’s Ruling in Wal-Mart Stores, Inc. v. Dukes and Later Cases
- [4.39] Dukes’ Impact on Courts’ Approaches to Bifurcating Discovery
- [4.40] “Headless” Class Actions and Discovery Regarding Replacement Class Representatives
- [4.41] Class Action Discovery and Mandatory Arbitration Agreements
- [4.42] Enforceability of Arbitration Clauses and Availability of Class Arbitration
- [4.43] Limitations of Discovery in Class Action Litigation Involving Arbitration Agreements
- [4.44] Class Arbitration and Discovery
- IV. [4.45] Specific Discovery Options
- Interrogatories
- [4.46] Federal Law
- [4.47] State Law
- [4.48] Depositions
- [4.49] Federal Law
- [4.50] State Law
- [4.51] Requests for Production of Documents or for Inspection of Things
- [4.52] Federal Law
- [4.53] State Law
- [4.54] Privilege Log
- [4.55] Requests To Admit
- [4.56] Federal Law
- [4.57] State Law
- [4.58] Contact with Class Members
- V. Discovery Disputes
- VI. [4.61] Conclusion
- VII. Appendix
- Chapter 5 — Class Action Notices Under Federal Rule of Civil Procedure 23
- I. [5.1] Equitable Common-Law Origins of Class Actions as They Relate to Notice
- II. Early Supreme Court Decisions and the Forerunners to Federal Rule of Civil Procedure 23
- III. Notice Requirements Under Federal Rule of Civil Procedure 23
- [5.4] General Observations
- [5.5] Mandatory Notice in Federal Rule of Civil Procedure 23(b)(3) Class Actions
- [5.6] Eisen v. Carlisle & Jacquelin
- [5.7] Phillips Petroleum Co. v. Shutts
- [5.8] Amchem Products, Inc. v. Windsor
- [5.9] 2003 Amendments
- [5.10] 2018 Amendments — Electronic Notice
- [5.11] Notice in Federal Rule of Civil Procedure 23(b)(1) and 23(b)(2) Class Actions
- Chapter 6 — Providing Notice of a Class Action
- Chapter 7 — Discretionary and Settlement Notices Under Federal Rules of Civil Procedure 23(c) – 23(e)
- I. Discretionary Notice Under Federal Rules of Civil Procedure 23(c)(2)(A) and 23(d)(1)(B)
- II. Settlement Notice Under Federal Rule of Civil Procedure 23(e)
- [7.6] In General
- Legal Considerations
- [7.7] Pre-Certification Settlements and Voluntary Dismissals
- [7.8] Involuntary Dismissals
- [7.9] Purpose of Notice
- Practical Considerations
- [7.10] Nature, Extent, and Manner of Settlement Notice
- [7.11] Contents of Notice
- [7.12] Time Limits
- [7.13] Recipients
- [7.14] Objections
- [7.15] Second Opt-Out Opportunity
- [7.16] Cost of Notice
- Chapter 8 — Pleadings, Motions, and Orders
- I. [8.1] Scope of Chapter — Federal and State Procedure
- II. [8.2] Class Action Complaint
- [8.3] Stating Claim for Class-Wide Relief
- Properly Pleading the Elements of Class Action
- [8.4] Alleging Class Definition
- [8.5] Alleging Numerosity
- [8.6] Alleging Common Questions of Law or Fact
- [8.7] Alleging Predominance
- [8.8] Alleging Typicality
- [8.9] Alleging Adequacy of Representation
- [8.10] Alleging Superiority of Class Action
- [8.11] Alleging Appropriateness Under the Illinois Rule
- [8.12] Federal Jurisdiction over Class Claims
- III. [8.13] Answers and Affirmative Defenses
- IV. [8.14] Counterclaims
- V. [8.18] Amendment of Pleadings
- VI. Motions in Class Action Cases
- VII. [8.23] Special Discovery Orders
- VIII. Motions for Class Certification and Decertification
- IX. [8.26] Orders Granting or Denying Motions for Class Certification
- X. Orders Directing Form and Manner of Notice
- XI. Settlement
- [8.32] Requirement of Notice of Proposed Settlement
- [8.33] Settlement with Class Before Class Certification
- [8.34] Settlement with Named Plaintiffs Alone; Settlement with Fewer than All Defendants
- [8.35] Illinois State Practice in Settlement, Compromise, and Dismissal of Class Actions
- [8.36] Opportunity To “Opt In” for Settlement
- [8.37] Filing Claim Forms
- [8.38] Objecting to Fairness of Settlement
- Chapter 9 — State Practice: Illinois’ Class Action Statute
- I. [9.1] Scope of Chapter
- II. [9.2] History of Statute
- III. Prerequisites for Maintenance of Class Action
- Generally
- [9.3] Numerosity, Common Questions, Adequate Representation, and Appropriate Method
- [9.4] Representative Party May Be Plaintiff or Defendant
- [9.5] Class Is So Numerous That Joinder of All Members Individually Is Impracticable
- [9.6] Common Questions of Law or Fact Predominate
- [9.7] Adequate Representation
- [9.8] Class Action Appropriate Method
- [9.9] Punitive Damages Class
- IV. [9.10] Order and Findings Relative to Class
- V. [9.11] Notice to Class
- VI. [9.12] Intervention by and Exclusion of Class Members
- VII. Binding Effect of Judgment
- [9.13] Absent Class Members May Be Bound
- [9.14] Extraterritorial Application of Decrees — National Class
- [9.15] Choice of Law
- [9.16] Nationwide Class Actions Under the Illinois Consumer Fraud and Deceptive Business Practices Act
- Special Principles Applicable to Class Actions
- [9.17] Tolling Statute of Limitations
- [9.18] Distribution of Residual Funds
- [9.19] Fluid Recovery
- VIII. [9.20] Compromise or Dismissal
- IX. [9.23] Appeal
- X. Federal Class Action Issues
- Chapter 10 — Settlement Procedures, Negotiations, and Agreements Under State and Federal Rules
- I. [10.1] Scope of Chapter
- II. Procedural Requirements
- III. Parties
- IV. Settlement Negotiations
- V. Settlement Agreement
- [10.10] Determination of the Class for Settlement Purposes Only
- [10.11] Claims To Be Settled and Released
- [10.12] Settlement Consideration
- [10.13] Cash and Recapture
- [10.14] Securities in a Stockholders’ Class Action
- [10.15] Compensation in Coupons
- [10.16] Nonmonetary Considerations
- [10.17] Adequacy of Consideration
- [10.18] Fee Agreement Provisions and Hearings on Fees
- [10.19] Criteria — Attorneys’ Fees
- [10.20] The Percentage-of-the-Fund Method
- [10.21] The Lodestar Method
- [10.22] Calculation of the compensable number of hours and the appropriate hourly rate
- [10.23] The weighted multiplier
- [10.24] The Class Action Fairness Act of 2005’s Provisions Relating to Class Settlements
- [10.25] Hearings on Fees
- [10.26] Persons Protected by the Settlement
- Stipulation of Settlement
- [10.27] Conditions for Effectiveness of Settlement
- [10.28] Sample Form of Stipulation of Settlement
- Chapter 11 — Settlement and Consideration (Notice, Standards of Judicial Evaluation, Settlement Hearing, and Judgment and Appeal)
- I. [11.1] Note Regarding 2018 Amendments to Federal Rule of Civil Procedure 23
- II. Notice to Class Members
- [11.2] Standard for Notice
- [11.3] Notice Requirements of Federal Rule of Civil Procedure 23(e)
- [11.4] Illinois Statutory Requirements
- [11.5] Class Action Fairness Act of 2005
- [11.6] Who Must Receive the Class Action Fairness Act of 2005 Notice
- [11.7] What the Notice Must Contain
- [11.8] Consequences of Failure To Comply with the Notice Requirements of the Class Action Fairness Act of 2005
- [11.9] Scope of the Class Action Fairness Act of 2005’s Settlement Notice Requirements
- Manner of Transmitting Notice to Class Members
- [11.10] Manner of Providing Notice Under Federal Rule of Civil Procedure 23(e)
- [11.11] Manner of Providing Notice Under 735 ILCS 5/2-806
- [11.12] Costs of Notice
- [11.13] Forms and Contents of Notice
- [11.14] Contents of Notice Under Federal Rule of Civil Procedure 23(e)
- [11.15] Contents of Notice Under the Class Action Fairness Act of 2005
- [11.16] Contents of Notice Under the Private Securities Litigation Reform Act of 1995
- [11.17] Contents of Notice Under 735 ILCS 5/2-806
- III. Standards for Judicial Evaluation and Approval of Settlements
- [11.18] Preliminary Determination That Proposed Settlement Is Within Range of Possible Approval
- [11.19] Appeal from Orders Authorizing or Denying Authorization for Mailing Notice of Proposed Settlement
- [11.20] General Standards for Judicial Evaluation and Approval of Proposed Class Action Settlement
- [11.21] Factors To Be Considered in Determining Whether Settlement Is Fair
- [11.22] Probabilities of Success on Issues of Liability and Damages Compared to the Amount Offered in Settlement
- [11.23] Other Factors Relating to the Court’s Fairness Analysis
- [11.24] Adequacy of Representation
- [11.25] Evidence of Collusion
- [11.26] Stage of the Proceeding and the Amount of Discovery Completed at the Time of the Settlement
- [11.27] Defendant’s Ability To Pay
- [11.28] Opinions of Counsel
- [11.29] Likely Complexity, Length, and Expense of Further Litigation
- [11.30] Opposition to Settlement from Members of the Class
- [11.31] Public Interest
- [11.32] Attorneys’ Fees
- [11.33] Equitable Treatment of Class Members
- [11.34] Miscellaneous Issues Relating to Judicial Approval of Class Action Settlements
- Cy Pres Settlements
- [11.35] Federal court practice
- [11.36] Residual funds and charitable organizations under 735 ILCS 5/2-807
- [11.37] Views of Interested Persons
- [11.38] Use of Court-Appointed Expert To Preview Economic and Similar Technical Data
- [11.39] Individual Settlement Offers and the Mootness Doctrine
- IV. Settlement Hearing
- V. Judgment and Appeal
- Chapter 12 — Complex and Multidistrict Actions
- I. Introduction
- II. Complex Cases
- [12.4] MANUAL FOR COMPLEX LITIGATION, FOURTH
- [12.5] Background of the MANUAL FOR COMPLEX LITIGATION, FOURTH
- [12.6] Scope of the MANUAL FOR COMPLEX LITIGATION, FOURTH
- General Principles of the MANUAL FOR COMPLEX LITIGATION, FOURTH
- [12.7] Judicial Supervision and Control
- [12.8] Early Identification and Control
- [12.9] Civil Cover Sheet Input Form — Northern District of Illinois
- [12.10] Practice in the Northern District of Illinois
- [12.11] Reassignment of Related Cases in the Northern District of Illinois
- [12.12] Assignment to Single Judge
- [12.13] Role of Counsel
- Pretrial Proceedings Under the MANUAL FOR COMPLEX LITIGATION, FOURTH
- [12.14] Initial Pretrial Conference
- [12.15] Case Management Conferences
- [12.16] Formulation of Issues
- [12.17] Discovery
- [12.18] Special Referrals
- [12.19] Final Pretrial Conference; Preparation for Trial
- [12.20] Final Pretrial Order Samples
- [12.21] Trial Preparations
- [12.22] Conduct of Trial
- [12.23] Presentation of Evidence
- [12.24] Jury Trial
- Class Actions
- [12.25] Special Procedural Requirements
- [12.26] Securities Litigation Uniform Standards Act of 1998
- [12.27] Class Action Fairness Act of 2005
- [12.28] Background
- [12.29] Expanded Federal Jurisdiction
- [12.30] Issues Under the Class Action Fairness Act
- [12.31] Class Action Fairness Act Settlement Requirements
- [12.32] Copycat Class Actions
- [12.33] Other Types of Complex Litigation
- [12.34] Alternative Dispute Resolution Considerations
- [12.35] Settlement
- [12.36] Judgments and Appeals
- [12.37] Possible Application of the MANUAL FOR COMPLEX LITIGATION, FOURTH, to State Court Proceedings
- [12.38] Summary
- III. Multidistrict Litigation
- [12.39] Categories of Complex Multidistrict Litigation
- Antitrust
- [12.40] The Electrical Equipment Litigation
- [12.41] Price-Fixing
- [12.42] Franchises
- Mass Disasters
- [12.43] Products Liability
- [12.44] Aircraft Crashes
- [12.45] Unusual Locations
- Business Disputes of National Scope
- [12.46] Securities Fraud
- [12.47] Employment Practices
- [12.48] Private Contracts
- [12.49] Government Regulations and Contracts
- [12.50] Patents, Trademarks, and Copyrights
- [12.51] Financial Institution Litigation
- [12.52] The First Question About Complex Multidistrict Litigation: To Sue or Not To Sue
- Alternative Procedures for Coordination or Consolidation of Multiple Litigations
- [12.53] State Court Cases and Informal Cooperation
- Removal and Remand Considerations
- [12.54] Class Action Fairness Act Removal to Federal Court
- [12.55] Remand to State Court
- [12.56] Appellate Review
- [12.57] Coordination by Assignment of Single Federal Judge
- Consolidation of Cases Within Division
- [12.58] Cases Before the Same Judge
- [12.59] Cases Before Different Judges
- [12.60] Limits
- [12.61] Transfer of Cases Between Divisions Within District
- Transfer of Cases to Other Districts
- [12.62] Forum Non Conveniens
- [12.63] Motions
- [12.64] Grounds
- [12.65] Choice of Laws
- [12.66] Appeal
- [12.67] Further Transfer
- [12.68] Transfer as Device for Cure of Venue Defects
- [12.69] Transfer for Coordinated or Consolidated Pretrial Proceedings
- Judicial Panel on Multidistrict Litigation
- [12.70] Composition
- [12.71] How the Judicial Panel on Multidistrict Litigation Gets Cases
- [12.72] Judicial Panel on Multidistrict Litigation Procedures — Rules of Procedure
- [12.73] Contact Information
- [12.74] Filing of Pleadings and Courtesy Copies
- [12.75] Judicial Panel on Multidistrict Litigation Rules on Form and Service of Pleadings and Motion Practice
- [12.76] Form of pleadings filed
- [12.77] Service of pleadings
- [12.78] Motion practice
- [12.79] Show-Cause Orders
- [12.80] Hearings
- [12.81] Applications for Time Extensions
- [12.82] Failure To Comply with the Judicial Panel on Multidistrict Litigation Rules
- [12.83] Effect of Pendency of Action Before the Judicial Panel on Multidistrict Litigation
- [12.84] Transfer and Retention of Records and Files
- [12.85] Scope of Judicial Panel on Multidistrict Litigation Jurisdiction
- [12.86] Effect of Judicial Panel on Multidistrict Litigation Transfer Orders
- [12.87] Tagalong Actions and Conditional Transfer Orders
- [12.88] Remand
- [12.89] Devices To Avoid Remand
- [12.90] Appeals of Panel Orders
- [12.91] Standards for Whether To Transfer
- [12.92] Private Civil Actions
- [12.93] Number of Actions
- [12.94] Pending in Different Jurisdictions
- [12.95] Common Questions of Fact
- [12.96] Complexity of Factual Questions
- [12.97] Efficient Conduct of Litigation
- [12.98] Conflicting Class Actions
- [12.99] Convenience of Parties and Witnesses
- [12.100] Outline of Considerations
- Selection of Transferee Court
- [12.101] Jurisdiction, Venue, and Choice of Laws
- [12.102] Cases on File
- [12.103] Progress of Cases on File
- [12.104] Central Location
- [12.105] Court Dockets
- Special Considerations for Certain Types of Cases
- [12.106] Antitrust
- [12.107] Common disasters
- [12.108] Patents, trademarks, and copyrights
- [12.109] Government regulations and contracts
- [12.110] Securities fraud
- Administration by Transferee Court
- [12.111] Discretion
- [12.112] Reconsideration of Decided Issues
- [12.113] Disposition by Transferee Court
- [12.114] Appeals During Transferred Proceedings
- [12.115] Conclusion
- Chapter 13 — Procedural Aspects of Shareholder Derivative Suits in Illinois
- I. [13.1] Introduction
- II. [13.2] Background
- III. Pretrial Procedures
- [13.3] Types of Actions/Joinder
- Jurisdiction
- [13.4] Subject-Matter Jurisdiction
- [13.5] Personal Jurisdiction
- [13.6] Service of Process
- [13.7] Venue — Forum Non Conveniens
- Prerequisites to the Maintenance of a Derivative Suit
- [13.8] Plaintiff Must Be a Shareholder
- [13.9] Plaintiff Must Own Stock at Time of Transaction of Which It Complains and During Pendency of Suit
- [13.10] Requirement of Demand on Directors
- [13.11] Excuse of Demand
- [13.12] Business-Judgment Rule
- [13.13] Requirement of Demand on Shareholders
- [13.14] Security for Costs
- [13.15] Pleading
- [13.16] Verification
- [13.17] Plaintiff’s Status as Shareholder
- [13.18] Collusion
- [13.19] Demand Efforts
- [13.20] Cause of Action in Favor of Corporation
- [13.21] Other Related Issues
- [13.22] Lead Plaintiff/Counsel in Derivative Action
- IV. Trial Issues
- V. Posttrial and Settlement Issues
- VI. [13.32] Some Ethical Considerations
- VII. [13.36] Taxpayer Actions
- Chapter 14 — The Class Action Fairness Act of 2005
- I. [14.1] Introduction
- II. [14.2] Effective Date
- III. Provisions Regarding Original and Removal Jurisdiction
- [14.3] Expansion of Federal Diversity Jurisdiction
- [14.4] General Standard: Minimal Diversity and $5 Million in Controversy
- [14.5] “Class Action” Defined
- Minimal Diversity
- [14.6] Minimal vs. Complete Diversity
- [14.7] Citizenship: Domicile vs. Residence
- [14.8] Dual Citizenship of Corporations and Unincorporated Associations
- [14.9] “Exceptions” to General Rule of Minimal Diversity
- District Court Obligation to Decline Jurisdiction
- Home-state exception: 28 U.S.C. §1332(d)(4)(B)
- [14.10] General standard
- [14.11] “Primary defendants”
- Local controversy exception: 28 U.S.C. §1332(d)(4)(A)
- [14.12] General standard
- [14.13] “Significant basis,” “significant relief,” and “principal injuries”
- [14.14] No similar class action filed within previous three years
- [14.15] District Court Discretion to Decline Jurisdiction: 28 U.S.C. §1332(d)(3)
- [14.16] Inapplicability of CAFA to Certain Class Actions: 28 U.S.C. §§1332(d)(5), 1332(d)(9)
- [14.17] Prerequisites vs. Exceptions to Jurisdiction
- [14.18] Amount in Controversy: $5 Million in the Aggregate
- Mass Actions
- [14.19] “Mass Actions” Defined
- [14.20] Claims Proposed To Be Tried Jointly
- [14.21] Exceptions
- Timing of Diversity/Amount-in-Controversy Determinations
- [14.22] General Rule: Jurisdiction Determined as of Time of Filing/Removal
- [14.23] Effect of Post-Filing or Post-Removal Amendments to Complaint
- [14.24] Effect of Denial of Class Certification
- [14.25] Effect of Stipulation to No CAFA Jurisdiction, Voluntary Dismissal, or “Splitting Up” Class Actions
- [14.26] Removal Jurisdiction Under CAFA
- [14.27] Statutory Removal Provisions
- [14.28] Any Defendant May Remove
- [14.29] No Requirement That All Defendants Consent to Removal
- [14.30] Timing of Removal
- [14.31] No Anti-Removal Presumption in CAFA Class Actions
- [14.32] Notice of Removal: No Evidence Required
- [14.33] Nonremovable Class Actions
- [14.34] Appellate Review of CAFA Remand Determinations
- Burden of Proof Under CAFA
- [14.35] Relationship to Pre-CAFA Law
- [14.36] General Rule
- [14.37] Burden of Proving Exceptions to CAFA Jurisdiction
- [14.38] Removal
- IV. [14.39] CAFA’S Class Action Settlement Provisions
- Coupon Settlements
- [14.40] Statutory Provisions
- [14.41] What Is a “Coupon”?
- [14.42] Potential Problems with Coupon Settlements
- [14.43] Judicial Scrutiny of Coupon Settlements
- Attorneys’ Fees in Coupon Settlements
- [14.44] Tying Attorneys’ Fees to Value of Coupons Redeemed
- [14.45] Valuing Coupon Settlements; Expert Testimony
- [14.46] Calculating Attorneys’ Fees: Redemption Value of Coupons or Lodestar Method
- [14.47] Timing of Payment of Attorneys’ Fees Award
- [14.48] Cy Pres Awards Based on Unclaimed Coupons
- [14.49] Other Protections for Settlement Class Members
- [14.50] Net Loss Settlements
- [14.51] Geographic Discrimination
- [14.52] CAFA Notice of Settlement to Federal and State Officials
- Appropriate Officials to Notify
- [14.53] Federal Official
- [14.54] State Official
- [14.55] Timing of Notice/Final Approval
- [14.56] Defendants Responsible for Sending Notice
- [14.57] Contents of Notice
- [14.58] Consequences of Failure To Provide Notice
- [14.59] Role of Government Officials in Settlement Approval Process
- Chapter 15 — Attorneys’ Fees in Class Actions
- I. [15.1] Introduction
- II. [15.2] History of Attorneys’ Fees in the Class Action Context
- III. [15.3] Bases for Awarding Attorneys’ Fees
- [15.4] Statutory Entitlements to Attorneys’ Fees from the Defendant
- [15.5] Civil Rights and Employment Discrimination Statutes
- [15.6] 42 U.S.C. §1988
- [15.7] Title VII of the Civil Rights Act of 1964
- [15.8] Equal Access to Justice Act; Substantially Justified Standard
- [15.9] Federal Consumer Protection Statutes — The Truth in Lending Act
- State Class Action Statutes
- [15.10] The Illinois Civil Rights Act of 2003
- [15.11] Illinois Consumer Fraud and Deceptive Business Practices Act
- [15.12] Who Is a “Prevailing Party”?
- [15.13] No Prevailing Party Status Under the Catalyst Theory
- [15.14] Common-Law Entitlements to Attorneys’ Fees
- [15.15] Common Fund Doctrine (Generating a Fee from the Recovery)
- [15.16] Substantial Benefit Doctrine
- [15.17] Private Securities Litigation Reform Act of 1995
- [15.18] Bad-Faith Doctrine
- [15.19] Private Attorney General Doctrine
- IV. [15.20] Calculating the Amount of the Attorneys’ Fees Award
- Discretion of the Court and Standard of Review
- [15.21] Trial Court
- Appellate Review
- [15.22] Timing the Notice of Appeal — A Trap for the Unwary
- [15.23] Review of the Award
- [15.24] Percentage Method
- [15.25] Calculating the Percentage: The Synthroid Marketing Cases
- [15.26] Fees Based on Gross vs. Net Recovery
- [15.27] Fees Paid in Stock
- [15.28] Coupon Settlements
- [15.29] Lodestar Method
- [15.30] Uses of the Lodestar Method
- [15.31] Calculating the Lodestar and Multiplier
- [15.32] Enhancement Limits: Blum v. Stenson
- [15.33] Third Circuit Task Force on Lodestar
- [15.34] Enhancement Limits Redux: Perdue v. Kenny A.
- [15.35] Percentage and Lodestar Methods in Various Jurisdictions
- [15.36] First Circuit
- [15.37] Second Circuit
- [15.38] Third Circuit
- [15.39] Fourth Circuit
- [15.40] Fifth Circuit
- [15.41] Sixth Circuit
- [15.42] Seventh Circuit
- [15.43] Eighth Circuit
- [15.44] Ninth Circuit
- [15.45] Tenth Circuit
- [15.46] Eleventh Circuit
- [15.47] D.C. Circuit
- [15.48] U.S. Court of Federal Claims and Federal Circuit
- [15.49] Illinois
- V. Miscellaneous Issues Unique to Class Litigation
- [15.50] Multiple Sources of Fees: Calculating the Fee When a Statutory Fee Case Also Produces a Common Fund
- [15.51] No “Proportionality” Requirement for Statutory Fees
- [15.52] Simultaneous Settlement Negotiations of Fees and Merits Issues: The Prandini Conflict
- [15.53] Reversionary Funds
- [15.54] Postjudgment Attorneys’ Fees
- [15.55] Incentive Fee Awards
- [15.56] Fees to Counsel for Objectors
- VI. [15.57] Conclusion
- Brent R. Austin
Brent R. Austin
Brent R. Austin is a Partner at Eimer Stahl LLP in Chicago, where he focuses on complex commercial litigation, class action and multidistrict litigation, antitrust, insurance industry business practices, securities and banking litigation, contract and commercial disputes, environmental, products liability and toxic torts, trademark, false advertising, and franchisor litigation. Mr. Austin received his B.A. summa cum laude from the University of California, Los Angeles, and his J.D. from the University of California, Berkeley, School of Law.
- Wilber H. Boies
Wilber H. Boies
Wilber H. Boies is Senior Counsel with McDermott Will & Emery, in Chicago, concentrating his practice in business litigation, including defense of class actions involving securities, employee benefits, and consumer fraud claims. Mr. Boies is the author of numerous articles on federal court litigation. He served as 1991 – 1992 Chair of the Chicago Bar Association’s Class Litigation Committee. Mr. Boies received his A.B. from Brown University and his J.D. from the University of Chicago Law School.
- Michael T. Brody
Michael T. Brody
Michael T. Brody is a Partner at Jenner & Block LLP in Chicago, concentrating his practice in appellate litigation and class action litigation. He is a Lecturer in Law at the University of Chicago Law School where he teaches a seminar class on class action controversies and is a Past President of the Seventh Circuit Bar Association. Mr. Brody received his B.A. from the University of Wisconsin–Madison and his J.D. from the University of Chicago Law School. Following law school, he clerked for Antonin Scalia, then a judge on the United States Court of Appeals for the District of Columbia Circuit.
- Daniel R. Campbell
Daniel R. Campbell
Daniel R. Campbell is a Partner at McDermott Will & Emery in Chicago, where he practices as a trial lawyer. He is a 2023 recipient of Crain’s Chicago Business 40 Under 40 award, a Cochair of the Chicago Bar Association Class Action Committee, and a Board Member of Legal Aid Chicago. Mr. Campbell received his two B.A.’s summa cum laude and with honors from the University of Missouri and his J.D. magna cum laude from the University of Illinois College of Law and has leadership and multicultural studies certificates.
- Matthew R. Devine
Matthew R. Devine
Matthew R. Devine is a Partner with Jenner & Block LLP in Chicago, where he focuses on class action practice, complex commercial litigation, and consumer law litigation. He has served on the Loyola University Chicago School of Law Alumni Board of Governors and as Past President of the Evanston Youth Hockey Association Board of Directors. He has been recognized as a Rising Star by Illinois Super Lawyers. He received his B.A. from University of Iowa and his J.D. cum laude from Loyola University Chicago School of Law.
- Vincent P. Formica, Jr.
Vincent P. Formica, Jr.
Vincent P. Formica, Jr., is an associate at Fuksa Khorshid LLC in Chicago, where he focuses on commercial litigation. He is a member of the Chicago Bar Association. Mr. Formica received his B.A. from Miami University and his J.D. magna cum laude from the University of Akron School of Law.
- Alexander N. Ghantous
Alexander N. Ghantous
Alexander N. Ghantous is a staff attorney at Jenner & Block LLP in Chicago where he concentrates his practice in litigation. He is a member of the Chicago Bar Association. Mr. Ghantous received his B.A. with honors from Columbia College Chicago and his J.D. from The UIC John Marshall Law School, where he received the CALI Excellence for the Future Award for Remedies and was recognized on the Dean’s List for the Spring and Fall of 2011.
- Thomas A. Haine
Thomas A. Haine
Thomas A. Haine is an associate at HeplerBloom, LLC, in Edwardsville where he concentrates on complex commercial litigation. He is a recipient of the Missouri Bar Foundation’s 2019 W. Oliver Rasch Award for outstanding articles. He is a member of the Order of the Coif of Washington University School of Law, and he served as Clerk for the Honorable Raymond P. Gruender, a judge on the United States Court of Appeals for the Eighth Circuit. Mr. Haine received his B.A. cum laude from Princeton University, his J.D. magna cum laude from Washington University School of Law, and his LL.M. from Catolica Global School of Law.
- Matthew T. Heffner
Matthew T. Heffner
Matthew T. Heffner is a Partner at Heffner Hurst in Chicago, where he focuses his practice on class action litigation. Mr. Heffner is an active member of the Northern District of Illinois Federal Trial Bar, for which he received the 2012 Northern District of Illinois Award for Excellence in Pro Bono Service. He is a Past Cochair of the Rule 23 subcommittee for the American Bar Association’s Class Action and Derivative Suit committee. Mr. Heffner received his B.A. from Indiana University, where he was an Arthur R. Metz Scholar, and his J.D. from University of Texas School of Law, where he was a Charles and Elizabeth Tigar Endowed Presidential Scholar.
- Aphrodite Kokolis
Aphrodite Kokolis
Aphrodite Kokolis is Counsel to ArentFox Schiff LLP in Chicago, where she concentrates her practice in commercial litigation with an emphasis on class actions and appeals. She received her J.D. Order of the Coif from Northwestern Pritzker School of Law, where she also served as Managing Editor of the Northwestern University Law Review.
- Clint Krislov
Clint Krislov
Clint Krislov (1949 – 2024) was the Founder and Senior Partner of Krislov Law: Krislov & Associates, Ltd., in Chicago. He was an adjunct professor at Chicago-Kent College of Law and the Founder and Director of Chicago-Kent’s Center for Open Government; he was also the creator and CEO of ConfirmDocs.com, a digital security site. He received the Legal Eagle Award: Independent Voters of Illinois-Independent Precinct Organization (2001) and the Amicus Curiae Award, presented by the Illinois Judges Association, and was involved in over 300 reported decisions. He was a member of the Chicago, Illinois State, and American Bar Associations, serving multiple terms as Chair and Vice Chair of the CBA Class Litigation Committee; the Decalogue Society; and the Rotary (Rotary/One Chicago, Paul Harris Fellow). Mr. Krislov received his B.A. from Northwestern University Phi Beta Kappa and his J.D. from Cornell University Law School.
- Christina T. Lopez
Christina T. Lopez
Christina T. Lopez is an associate at Jenner & Block LLP in Chicago, where she concentrates in litigation. Ms. Lopez received her B.A. summa cum laude from University of Illinois at Urbana-Champaign, where she is listed on the Bronze Tablets for University Honors and was recognized as a Robert H. Bierma Scholar, and her J.D. cum laude from Northwestern University School of Law, where she was a recipient of the Harold Washington Leadership Award and served as notes editor of the Northwestern Journal of Technology and Intellectual Property.
- Kevin R. Malloy
Kevin R. Malloy
Kevin R. Malloy is an associate at Forde & O’Meara LLP in Chicago, where he concentrates his practice in commercial litigation and appeals. He is a member of the Appellate Lawyers Association, the Chicago Bar Association (where he served as an investigator with the Judicial Evaluation Committee), and the Illinois State Bar Association. He was rated as a Super Lawyer in business litigation in 2024. Mr. Malloy received his B.A. from the University of Notre Dame and his J.D. cum laude from the American University Washington College of Law.
- William E. Meyer, Jr.
William E. Meyer, Jr.
William E. Meyer, Jr., is Of Counsel to Fuksa Khorshid LLC in Chicago, where he focuses his practice in general commercial litigation. He is a member of the Illinois State and Lake County Bar Associations. He received his A.B. from Harvard College, his J.D. from Loyola University Chicago School of Law, and his M.B.A. from the University of Chicago Booth School of Business with an elective in advanced finance and ethics.
- Thomas E. Quinn
Thomas E. Quinn
Thomas E. Quinn is an associate at Jenner & Block LLP in Chicago, where he focuses on commodities and derivatives litigation, regulatory defense, and antitrust litigation. He is admitted to the U.S. District Court, Northern and Southern Districts of Illinois, and the U.S. Court of Appeals Seventh Circuit. Mr. Quinn received his B.A. with honors from Haverford College and his J.D. from Stanford Law School, where he was an associate editor of Stanford Law & Policy Review.
- W. Jason Rankin
W. Jason Rankin
W. Jason Rankin is a Partner at HeplerBroom LLC in Edwardsville, where he focuses his practice on class and mass tort actions and pharmaceutical and medical devices. He is a Past Chair of the DRI Class Action Specialized Litigation Group, a Past Program Chair of the DRI Class Actions Seminar on Latest Developments in Law and Practice, and a member of the Illinois Defense Counsel and the International Association of Defense Counsel. Mr. Rankin received his J.D. from Washington University School of Law.
- Paul B. Rietema
Paul B. Rietema
Paul B. Rietema is a Partner at Jenner & Block LLP in Chicago, where his practice is focused on business litigation and arbitration and class action litigation. He has been recognized in Best Lawyers in America for Commercial Litigation from 2021 to 2024 and received the Exceptional Service Award in 2016 from the American Bar Association. Mr. Rietema received his J.D. cum laude from Harvard Law School.
- Adam Safer
Adam Safer
Adam Safer is an associate at McDermott Will & Emery in Chicago, where he concentrates on litigation. He clerked for the Honorable Sara L. Ellis, a judge on the United States District Court of the Northern District of Illinois. He received his B.A. from Denison University and his J.D. from The New York University School of Law.
- Howard S. Suskin
Howard S. Suskin
Howard S. Suskin is a Partner at Jenner & Block LLP in Chicago, where he serves as Cochair of the Securities Litigation and Class Action Practice Groups. He is Chambers USA Ranked, has been recognized by Best Lawyers in America, and is General Counsel to the Chicago Bar Association. Mr. Suskin received his B.A. with honors from Northwestern University, where he was elected to Phi Beta Kappa, and his J.D. with honors from the University of Michigan Law School, where he was Editor of the Michigan Law Review.
- Charles R. Watkins
Charles R. Watkins
Charles R. Watkins is Of Counsel to Guin, Stokes & Evans, LLC, in Oak Park, where he concentrates his practice on class action litigation. In 2024, he received an Attorney of the Year award from Minnesota Lawyer magazine for his work on Tyler v. Hennepin County, decided by the United States Supreme Court, finding certain Minnesota tax foreclosure statutes unconstitutional. Mr. Watkins received his B.A. with high honors from Michigan State University and his J.D. cum laudefrom the University of Michigan Law School.
Class Actions (ARCHIVED 2020 EDITION)
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