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

Paid petition · United States Court of Appeals for the Third Circuit, No. 20-2431, 23-1291 · judgment September 20, 2024


Certiorari denied · March 31, 2025
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

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?

Counsel of record

For petitioner
Ira Neil Richards
Dilworth Paxson LLP

For respondent
Douglas A. Clark
The Clark Law Firm, PC

Case

Conference history
Distributed for 2 conferences

Proceedings

  1. Mar 31 2025
    Petition DENIED.
  2. Mar 12 2025
    DISTRIBUTED for Conference of 3/28/2025.
  3. Mar 10 2025
    Reply of petitioners Martha Adams, et al. filed. (Distributed)
  4. Feb 26 2025
    Brief of respondents Angelo Rescigno, Sr., et al. in opposition filed.
  5. Feb 26 2025
    Brief of respondent Equinor USA Onshore Properties in opposition filed.
  6. Jan 27 2025
    Response Requested. (Due February 26, 2025)
  7. Jan 22 2025
    DISTRIBUTED for Conference of 2/21/2025.
  8. Jan 21 2025
    Waiver of right of respondent Angelo Rescigno, Sr., as Executor of the Estate of Cheryl B. Canfield, et al. to respond filed.
  9. Jan 10 2025
    Petition for a writ of certiorari filed. (Response due February 14, 2025)