605 U.S. 327
SCOTUS2025Background
- LabCorp introduced self-service check-in kiosks at diagnostic laboratories, which were not independently accessible to blind and visually impaired patients.
- To address accessibility, LabCorp maintained front-desk services for those needing or preferring assistance.
- Legally blind plaintiffs sued LabCorp, alleging violations of the ADA and California’s Unruh Civil Rights Act due to inaccessible kiosks, seeking statutory damages via a class action.
- The district court certified a class of all legally blind individuals in California denied full and equal enjoyment due to kiosk inaccessibility.
- LabCorp challenged the class certification, arguing it included uninjured members (e.g., those who didn't use or intend to use kiosks), but the Ninth Circuit approved it, referencing circuit precedent allowing classes with some uninjured members.
- The Supreme Court granted certiorari on whether a damages class under Rule 23 may include both injured and uninjured members, but then dismissed the case as improvidently granted, leaving the underlying question unresolved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a damages class under Rule 23 can include uninjured class members | Class can include some uninjured members | Class must exclude uninjured members | Case dismissed as improvidently granted; no decision |
| Procedural mootness—whether appeal was of the correct order | LabCorp appealed wrong order | Proper appeal of original cert order | Not resolved; Court did not address mootness |
| Ninth Circuit precedent on de minimis uninjured members | De minimis exception applies | No exception; all must be injured | Not addressed; dissent would have rejected de minimis |
| Impact on businesses and class actions | Not central to claim | Overbroad classes risk coercive settlements | Not addressed; discussed in dissent |
Key Cases Cited
- Comcast Corp. v. Behrend, 569 U.S. 27 (limits Rule 23(b)(3) damages classes to those with predominance of common injury)
- Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (commonality and predominance are crucial for class certification)
- Amchem Products, Inc. v. Windsor, 521 U.S. 591 (emphasizes predominance in class actions)
- General Telephone Co. of Southwest v. Falcon, 457 U.S. 147 (tight standards for certifying class actions)