Phillip Alig v. Rocket Mortgage, LLC, 126 F.4th 965

Plaintiffs (Alig and Shea families) refinanced their mortgages with Quicken Loans in West Virginia and paid for home appraisals.
Quicken Loans included borrowers' own estimated home values on appraisal request forms sent to appraisers, a common pre-2009 industry practice.
Plaintiffs alleged appraisals were not truly "independent" and thus were "worthless," constituting unconscionable inducement, breach of contract, and conspiracy under West Virginia law.
The district court certified a class of 2,769 West Virginia borrowers and awarded over $10.6 million in damages to the class for statutory violations and breach of contract.
On appeal, the Fourth Circuit initially affirmed class certification and liability but the Supreme Court vacated and remanded for reconsideration in light of TransUnion LLC v. Ramirez, raising the bar for Article III standing in class actions.
On further review, the Fourth Circuit decertified the class, holding the plaintiffs failed to show that all class members suffered concrete harm sufficient for standing, though the named plaintiffs could proceed on their individual claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing—Class Action Damages	All class members paid for independent appraisals not received, hence concrete financial harm.	Not all class members suffered concrete injury; only risk of harm alleged.	No standing for class; insufficient proof of concrete harm for all members.
Statutory Unconscionability (W. Va. Code § 46A-2-121)	Loans induced by undisclosed, unconscionable appraisal practices.	Plaintiffs received benefits; appraisals were performed independently.	Affirmed for named plaintiffs; reversed for class.
Breach of Contract	Contract required fair/independent appraisal; violated by practices.	No proof appraisals were not independent or that damages occurred.	Remanded for fact-specific review for named plaintiffs.
Civil Conspiracy	Title Source, as affiliate, shared liability for unconscionable conduct.	No actionable underlying conduct or damages for the class.	Affirmed liability for named plaintiffs, not the class.

TransUnion LLC v. Ramirez, 594 U.S. 413 (2021) (class action standing requires proof of concrete harm for each class member)
Tyson Foods, Inc. v. Bouaphakeo, 577 U.S. 442 (2016) (federal courts lack authority to award relief to uninjured plaintiffs in class actions)
McFarland v. Wells Fargo Bank, N.A., 810 F.3d 273 (4th Cir. 2016) (borrower typically not disadvantaged by under-collateralized loan in typical mortgage transactions)
Alig v. Quicken Loans Inc., 990 F.3d 782 (4th Cir. 2021) (original appellate decision on this underlying dispute, ultimately vacated by Supreme Court)