“Two Wrongs Don’t Make a Right, But a Few More Can Make a Unicorn”Class actions typically involve a proposed class of plaintiffs seeking recovery from the same defendant on similar grounds. But that is not the only animal in the class action corral. Rule 23 makes this clear in its very first sentence: One or more members of a class may sue or be sued as representative parties

Courts are still going both ways on applying Bristol-Myers Squibb to class actions. Two recent decisions highlight this split.

<i>Bristol-Myers Squibb</i> Continues to Be a Mixed Bag in the Class Action ContextThe first—and we’ll always start with the good news—comes out of the District of Massachusetts in Roy v. FedEx Ground Package System, Inc. There, the court held that Bristol-Myers Squibb applies to collective actions under the

Court Strikes Non-Forum Class Members’ Claims in TCPA Class Action under <i>Bristol-Myers Squibb</i>We have been closely watching how courts have applied the Supreme Court’s Bristol-Myers Squibb decision in the class action context, and the early results are mixed. But the Northern District of Illinois made a big step in the right direction when it decided America’s Health and Resource Center, Ltd. v. Promologics, Inc. The court