美国实验室控股公司诉戴维斯案

In 2017, Labcorp introduced self-service check-in kiosks. Legally blind plaintiffs Luke Davis and Julian Vargas, joined by the American Council of the Blind, sued Labcorp in the U.S. District Court for the Central District of California in January 2020, claiming the kiosks violated the ADA and California‘s Unruh Civil Rights Act, which provides a minimum of $4,000 in statutory damages per violation. In May 2022, District Judge Fernando M. Olguin certified a damages class of all legally blind individuals in California who were unable to use the kiosks, with potential damages up to about $500 million per year. The Ninth Circuit affirmed, holding that Rule 23 permits certification even if the class “potentially includes more than a de minimis number of uninjured class members”. Labcorp petitioned the Supreme Court, which granted certiorari on January 24, 2025. Oral argument was held on April 29, 2025. On June 5, 2025, the Supreme Court dismissed the writ as improvidently granted in an 8-1 per curiam decision, leaving the Ninth Circuit‘s decision in place.

The Supreme Court dismissed the writ of certiorari as improvidently granted in an 8-1 per curiam decision, declining to decide the merits of the class certification question. Justice Kavanaugh filed a sole dissent, arguing the Court should have held that federal courts may not certify damages classes that include uninjured members because common questions would not predominate under Rule 23(b)(3).

Whether a federal court may certify a damages class pursuant to Federal Rule of Civil Procedure 23 when the class includes both injured and uninjured class members, some of whom lack Article III standing.

The decision left unresolved a significant circuit split: the Ninth and Eleventh Circuits generally permit certification with potentially uninjured members, while the Second, Fourth, and Eighth Circuits generally bar it. This creates ongoing uncertainty for businesses facing class actions. Justice Kavanaugh warned that overbroad class certifications expose businesses to massive liability and coerce settlements regardless of merits, with ripple effects on consumers, retirement account holders, and employees through higher prices, lower returns, and reduced benefits.