United States Second Circuit

In this class action, plaintiff-employees brought suit against defendants, alleging breach of fiduciary duty, legal malpractice, and breach of contract. The district court granted plaintiffs' motion for class certification, and in doing so, applied New York law to all of the class members' claims, even though the class members hailed from twenty-seven different states. The district court further held that common issues predominated over any individual issues, even though prior litigation in state court indicated that for class members from Colorado, individual waivers could have vitiated defendants' liability. The district court's class certification order is vacated and the case is remanded, where the district court erred in its choice-of-law analysis, and a proper analysis makes it clear that the individual issues in this case will predominate over the common issues that plaintiffs have identified.

Appellate Information

• Decided 03/04/2015
• Published 03/04/2015

Judges

Court

• United States Second Circuit

Counsel