Wilson v. Centene Mgmt
Split Score
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This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Vacated
The Fifth Circuit held that the district court erred in denying class certification on standing grounds in a suit alleging that Ambetter health-insurance directories were materially inaccurate, causing policyholders to overpay. Concluding that the plaintiffs sufficiently established individual and class standing, the court vacated the order denying certification and remanded for the district court to address Rule 23 requirements.
Circuit Split Identified
Legal Issue
Whether, in putative class actions, a court should evaluate unnamed class members' injuries under Rule 23 criteria after the named plaintiff establishes personal standing (the "class-certification approach") or instead require the named plaintiff to demonstrate Article III standing for each claim on behalf of the entire class (the "standing approach").
Circuit Positions
Class-certification approach – once the named plaintiff has Article III standing, remaining issues go to Rule 23 analysis.
Standing approach – the named plaintiff must independently show Article III standing for each class claim before Rule 23 certification.
Undecided; analyzes both approaches without adopting either.
Conflict Summary
Some circuits hold that once the named plaintiff personally satisfies Article III, any mismatch between the named plaintiff’s injury and those of absent class members is handled exclusively under Rule 23 (class-certification approach). Other circuits require the named plaintiff to demonstrate Article III standing with respect to each claim or product affecting the entire class before Rule 23 issues are considered (standing approach). The Fifth Circuit, in this opinion, acknowledges the split and continues to analyze both tests without choosing between them.