Labcorp argues before U.S. Supreme Court that all class members must have standing

Client(s) Laboratory Corporation of America Holdings

On behalf of Laboratory Corporation of America Holdings, Jones Day urged the U.S. Supreme Court to overrule a Ninth Circuit decision holding that district courts can certify damages class actions under Rule 23(b)(3) even when the class contains members who lack an Article III injury. This case has major implications for standing jurisprudence as well as class actions more generally.

In a California district court, plaintiffs brought a multibillion dollar class action on behalf of a putative class of all legally blind individuals who visited a Labcorp location with a check-in kiosk alleged to be inaccessible. Plaintiffs sought to certify the class despite Labcorp’s objection that it contained many members who suffered no injury, such as patients without any interest in using a kiosk to check in. The district court still certified the class, and the Ninth Circuit affirmed.

At the Supreme Court, Jones Day argued that Article III of the Constitution forbids the uninjured from pursuing damages in federal court, whether they bring those claims through the front door of the courthouse as named plaintiffs or smuggle them in through the back door as unnamed class members. At the very least, the number of mini-trials that would be needed to find and remove the uninjured class members before resolution of the merits would overwhelm the case and make class-certification improper under Federal Rule of Civil Procedure 23(b)(3).

Laboratory Corporation of America Holdings v. Davis, No. 24-304 (U.S.)