predominance requirement (Iowa) · Go Syfert
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predominance requirement in Iowa

7 Iowa opinions name it 2 courts 2005–2024 2 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Vos v. Farm Bureau Life Insurance Co.green
iowa · 2003 · cited in 5 Iowa opinions naming this issue, 2017–2024
2 sentences

2024“A claim will meet the predominance requirement when there exists generalized evidence which proves or disproves an element on a simultaneous, classwide basis, since such proof obviates the need to examine each class member’s individual position.” Id. at 119 (quoting Vos, 667 N.W.2d at 45 ).

2021However, “[a] claim will meet the predominance requirement when there exists generalized evidence which proves or disproves an element on a simultaneous, class-wide basis, since such proof obviates the need to examine each class member’s individual position.” Vos, 667 N.W.2d at 45 (citation omitted).

15
Leonard J. Klay v. Humana, Inc.green
ca11 · 2004 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Express Corp., 576 F.3d 1183 , 1191–92, 1195 (11th Cir. 2009) (affirming denial of class certification and concluding the predominance requirement was not met by hourly employees alleging failure to pay “gap periods” because no common proof of uncompensated time existed and individualized inquiries would be required); Klay v. Humana, Inc., 382 F.3d 1241, 1267 (11th Cir. 2004) (holding the district court abused its discretion in certifying doctors’ breach of contract claim against health maintenance organizations when individualized issues predominated, notwithstanding contract claims common to

11
Bridge v. Phoenix Bond & Indemnity Co.green
scotus · 2008 · cited in 1 Iowa opinions naming this issue, 2020–2020
2 sentences

2020Co., 553 U.S. 639, 661 , 128 S. Ct. 2131, 2145 (2008); In re FedEx Ground Package Sys., Inc., 662 F. Supp. 2d 1069, 1092 (N.D.

2020Co., 553 U.S. 639, 661 , 128 S. Ct. 2131, 2145 (2008); In re FedEx Ground Package Sys., Inc., 662 F. Supp. 2d 1069, 1092 (N.D.

11
In Re Fedex Ground Package System, Inc., Employment Practices Litigationgreen
innd · 2009 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Co., 553 U.S. 639, 661 , 128 S. Ct. 2131, 2145 (2008); In re FedEx Ground Package Sys., Inc., 662 F. Supp. 2d 1069, 1092 (N.D.

11
In re Potash Antitrust Litigationgreen
mnd · 1995 · cited in 1 Iowa opinions naming this issue, 2005–2005
2 sentences

2005These three issues involve alleged statutory violations, which are “clearly ... legal question[s]” and are “classic issue[s] that [are] considered common to a class.” Luttenegger, 671 N.W.2d at 440 ; accord Martin, 435 N.W.2d at 368 (holding that breach of implied warranty constituted common question); Vignaroli, 360 N.W.2d at 744 ^5 (holding that plaintiffs’ reliance on written provisions in defendant’s employment manual constituted the “gist of their claim”); see also In re Potash Antitrust Litig., 159 F.R.D. 682, 693 (D.Minn.1995) (“[C]onsidering the facts of the case presented, a claim wil

2005These three issues involve alleged statutory violations, which are “clearly ... legal question[s]” and are “classic issue[s] that [are] considered common to a class.” Luttenegger, 671 N.W.2d at 440 ; accord Martin, 435 N.W.2d at 368 (holding that breach of implied warranty constituted common question); Vignaroli, 360 N.W.2d at 744 ^5 (holding that plaintiffs’ reliance on written provisions in defendant’s employment manual constituted the “gist of their claim”); see also In re Potash Antitrust Litig., 159 F.R.D. 682, 693 (D.Minn.1995) (“[C]onsidering the facts of the case presented, a claim wil

11
Martin v. Amana Refrigeration, Inc.green
iowa · 1989 · cited in 1 Iowa opinions naming this issue, 2005–2005
1 sentence

2005These three issues involve alleged statutory violations, which are “clearly ... legal question[s]” and are “classic issue[s] that [are] considered common to a class.” Luttenegger, 671 N.W.2d at 440 ; accord Martin, 435 N.W.2d at 368 (holding that breach of implied warranty constituted common question); Vignaroli, 360 N.W.2d at 744 ^5 (holding that plaintiffs’ reliance on written provisions in defendant’s employment manual constituted the “gist of their claim”); see also In re Potash Antitrust Litig., 159 F.R.D. 682, 693 (D.Minn.1995) (“[C]onsidering the facts of the case presented, a claim wil

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Laurie Freeman, Sharon Mockmore, Beccy Boysel, Gary D. Boysel, Linda L. Goreham, Gary R. Goreham, Kelcey Brackett, and Bobbie Lynn Weatherman v. Grain Processing Corporation green
iowa · 2017
2 sentences

2024“A claim will meet the predominance requirement when there exists generalized evidence which proves or disproves an element on a simultaneous, classwide basis, since such proof obviates the need to examine each class member’s individual position.” Id. at 119 (quoting Vos, 667 N.W.2d at 45 ).

2019Roland can satisfy the predominance requirement by pointing to “generalized evidence which proves or disproves an element on a simultaneous, classwide basis, since such proof obviates the need to examine each class member’s individual position.” See Freeman, 895 N.W.2d at 119 (quoting Vos, 667 N.W.2d at 45 ).

22019–2024
Karl Ebert v. General Mills, Inc. green
ca8 · 2016
2 sentences

2017The predominance inquiry is “qualitative rather than quantitative”; merely “a common question does not end the inquiry.” Ebert, 823 F.3d at 478 ; see also William B. 21 Rubenstein, Newberg on Class Actions § 4:50 (5th ed.), Westlaw (database updated Dec. 2016) [hereinafter Newberg].

2017The predominance inquiry is “qualitative rather than quantitative”; merely “a common question does not end the inquiry.” Ebert, 823 F.3d at 478 ; see also William B. 21 Rubenstein, Newberg on Class Actions § 4:50 (5th ed.), Westlaw (database updated Dec. 2016) [hereinafter Newberg].

22017–2017
Babineau v. Federal Express Corp. green
ca11 · 2009
1 sentence

2020Express Corp., 576 F.3d 1183 , 1191–92, 1195 (11th Cir. 2009) (affirming denial of class certification and concluding the predominance requirement was not met by hourly employees alleging failure to pay “gap periods” because no common proof of uncompensated time existed and individualized inquiries would be required); Klay v. Humana, Inc., 382 F.3d 1241, 1267 (11th Cir. 2004) (holding the district court abused its discretion in certifying doctors’ breach of contract claim against health maintenance organizations when individualized issues predominated, notwithstanding contract claims common to

12020–2020
Vignaroli v. Blue Cross of Iowa green
iowa · 1985
1 sentence

2005These three issues involve alleged statutory violations, which are “clearly ... legal question[s]” and are “classic issue[s] that [are] considered common to a class.” Luttenegger, 671 N.W.2d at 440 ; accord Martin, 435 N.W.2d at 368 (holding that breach of implied warranty constituted common question); Vignaroli, 360 N.W.2d at 744 ^5 (holding that plaintiffs’ reliance on written provisions in defendant’s employment manual constituted the “gist of their claim”); see also In re Potash Antitrust Litig., 159 F.R.D. 682, 693 (D.Minn.1995) (“[C]onsidering the facts of the case presented, a claim wil

12005–2005
Luttenegger v. Conseco Financial Servicing Corp. green
iowa · 2003
1 sentence

2005These three issues involve alleged statutory violations, which are “clearly ... legal question[s]” and are “classic issue[s] that [are] considered common to a class.” Luttenegger, 671 N.W.2d at 440 ; accord Martin, 435 N.W.2d at 368 (holding that breach of implied warranty constituted common question); Vignaroli, 360 N.W.2d at 744 ^5 (holding that plaintiffs’ reliance on written provisions in defendant’s employment manual constituted the “gist of their claim”); see also In re Potash Antitrust Litig., 159 F.R.D. 682, 693 (D.Minn.1995) (“[C]onsidering the facts of the case presented, a claim wil

12005–2005

Where else courts name it

OH 80 (1987–2025) TX 77 (2000–2024) AR 32 (1997–2024) CA 29 (1989–2026) LA 21 (1997–2024) IL 20 (2006–2025) NJ 17 (1997–2020) AL 16 (1996–2014) FL 14 (2005–2026) WV 10 (2010–2022) MO 10 (2007–2024) CO 9 (2009–2024) MA 9 (1999–2016) IN 9 (1979–2020) KY 8 (2019–2025) NY 8 (1980–2010) IA 7 (2005–2024) CT 7 (2003–2018) WA 6 (2010–2021) GA 6 (2007–2020) NM 6 (2004–2018) OR 6 (1995–2026) RI 5 (1999–2003) PA 5 (1999–2023) NC 5 (2012–2022) OK 4 (2003–2022) MD 4 (1995–2020) ME 4 (2000–2023) MN 2 (2002–2009) TN 2 (2022–2024) NH 2 (2007–2012)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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