Laboratory Corp. of America Holdings v. Davis
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Laboratory Corp. of America Holdings v. Davis and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Laboratory Corp. of America Holdings v. Davis.
In Laboratory Corp. of America Holdings v. Davis, the Supreme Court dismissed the writ of certiorari as improvidently granted, leaving unresolved the question of whether a federal court may certify a damages class under Federal Rule of Civil Procedure 23 when the class includes both injured and uninjured members. The case involved Labcorp's introduction of self-service kiosks, which allegedly violated the Americans with Disabilities Act and California's Unruh Civil Rights Act. The Ninth Circuit had previously upheld the class certification, allowing for potential damages of up to $500 million per year.
Holding
The single most important “bottom line” of what the Court decided in Laboratory Corp. of America Holdings v. Davis.
The Court held that the writ of certiorari was dismissed as improvidently granted, leaving the question of class certification unresolved.
Constitutional Concepts
These are the Constitution-related themes that appear in Laboratory Corp. of America Holdings v. Davis. Click a concept to see other cases that involve the same idea.
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Why Due Process is relevant to Laboratory Corp. of America Holdings v. Davis
The case involves the procedural aspects of class certification under Rule 23, which relates to the due process rights of class members and defendants.
Syllabus excerpt (verbatim)Federal courts may not certify a damages class under Rule 23 when, as here, the proposed class includes both injured and uninjured class members.
Key Quotes
Short excerpts from the syllabus in Laboratory Corp. of America Holdings v. Davis that support the summary and concepts above.
The writ of certiorari is dismissed as improvidently granted.
Federal courts may not certify a damages class under Rule 23 when, as here, the proposed class includes both injured and uninjured class members.
Classes that are overinflated with uninjured members raise the stakes for businesses that are the targets of class actions.