Martha Adams, et al. v. Angelo Rescigno, Sr., as Executor of the Estate of Cheryl B. Canfield, et al.

This Petition arises out of a class settlement of a claim that the defendant breached a variety of leases by the method it used to pay royalties for natural gas production. The court of appeals affirmed the district court’s settlement class certification and settlement approval based on two critical legal determinations. First, the court of appeals made a policy determination, without considering the text of Federal Rule of Civil Procedure 23 as amended in 2018, that settlements of class actions should be strongly favored, with class settlements presumed fair. Two other circuits, the Second and the Ninth, have reached the opposite conclusion after examining the Rule’s text. Second, the court of appeals declined to follow this Court’s decision in TransUnion v. Ramirez, 594 U.S. 413 (2021). Instead, it held that entry of a judgment for a settlement class requires only that the named plaintiff has alleged an individual injury, without any need to determine whether the settlement class excludes the uninjured. The questions presented are:

1. Does Federal Rule of Civil Procedure 23 as amended in 2018 permit courts to apply a policy favoring settlement in place of a rigorous evidentiary analysis before certifying a settlement class and approving a class settlement?

2. Does Article III of the Constitution permit a court to certify a settlement class and enter judgment where the settlement class definition does not exclude anyone without a concrete injury?