Gooch v. Life Investors Insurance Co. of America
672 F.3d 402
| 6th Cir. | 2012Background
- Gooch holds a cancer-only policy with Life Investors; Life Investors previously paid list prices, then changed to pay based on 'proof of loss'.
- Policy defines 'actual charges' and 'usual and customary' with several terms left undefined; Gooch seeks list-price payments.
- Arkansas Runyan class action settled; Runyan settlement approved with a fee cap and broad release; Gooch opted out.
- District court twice certified a class in this case, then vacated/dismissed reconsideration; Life Investors sought dissolution of preliminary injunction.
- This appeal concerns preclusion effects of Runyan on Gooch’s class, jurisdiction to dissolve injunction, and ongoing class certification issues.
- Court holds Runyan precludes most claims, vacates class certification, but remands for possible remnant class actions; dismisses appeal on dissolution of injunction for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Runyan preclude Gooch's class action here? | Gooch argues Runyan does not bind this class due to different class definitions. | Life Investors contends Runyan precludes most or all claims and requires dismissal of certification. | Runyan precludes most claims; vacate class certification and remand. |
| Is Life Investors' motion to dissolve the injunction appealable under 28 U.S.C. § 1292(a)(1)? | Gooch argues jurisdiction exists as an injunction-modification appeal. | Life Investors asserts interlocutory appeal permitted for dissolving or modifying injunctions. | Appeal dismissed for lack of jurisdiction. |
| Did Runyan meet due-process and full-faith-and-credit requirements for preclusion? | Gooch contends Runyan's settlement may not satisfy due process for collateral attack. | Life Investors argues Runyan satisfied due process and would be given full faith and credit. | Runyan satisfies due process and Arkansas preclusion should be given full faith and credit. |
| Is declaratory relief under Rule 23(b)(2) proper after Wal-Mart given potential damages claim? | Gooch seeks declaratory relief on contract interpretation applicable to all class members. | Life Investors argues Wal-Mart limits 23(b)(2) when damages may be involved. | Declaratory relief under 23(b)(2) permissible; separate monetary subclass under 23(b)(3) contemplated. |
| Are Gooch’s Rule 23(a) adequacy and typicality satisfied given Runyan's preclusion and class dynamics? | Gooch argues he is typical and adequate as class representative. | Life Investors asserts conflicts and credibility concerns undermine adequacy. | Gooch satisfies Rule 23(a); some caveats noted but not sufficient to deny adequacy. |
Key Cases Cited
- Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (2011) (monetary claims and predominance in 23(b)(2) context; declaratory relief as appropriate)
- Beattie v. CenturyTel, Inc., 511 F.3d 554 (6th Cir. 2007) (rigorous analysis required for class certification; abuse of discretion standard)
- Szabo v. Bridgeport Machs., Inc., 249 F.3d 672 (7th Cir. 2001) (presumption vs. proof in class certification; caution against presuming allegations true)
- Hansberry v. Lee, 311 U.S. 32 (1940) (due process and collateral attacks on judgments require full scrutiny)
- Matsushita Elec. Indus. Co. v. Epstein, 516 U.S. 367 (Supreme Court 1996) (full faith and credit limitations; context for class-action settlements)