Courts of Appeal Clarify: Class Representatives from Every State Are Not Necessarily Required for Multistate Class Actions

Opinions warn against conflating FRCP 23 elements with constitutional standing. Defendants battling proposed class actions based on alleged violations of state law have long argued that any certified class should be limited to residents of the states in which the named plaintiffs reside. Absent class members from other states should be excluded, they urge, because the named plaintiffs supposedly only