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February 2014: Class Decertification Victory for State Farm

February 2014

In an extremely important victory for client State Farm Mutual Automobile Insurance Company, Quinn Emanuel convinced the Ohio Supreme Court to reverse certification of a class of approximately 100,000 Ohio State Farm policyholders seeking to recover more than $100 million in compensatory damages, as well as punitive damages.

In that case, the named plaintiff, Michael Cullen, brought suit on behalf of himself and other State Farm policyholders whose windshield repairs had been paid for by State Farm over a twenty-year period. The plaintiff claimed that under their State Farm policies he and the class members were entitled to cash payments in the amount of the cost of a windshield replacement. The plaintiff asserted claims for breach of contract, bad faith, and breach of fiduciary duty. The trial court granted class certification under Ohio Rules 23(B)(3) and 23(B)(2). The Ohio Court of Appeals affirmed class certification.

In its 22-page opinion issued on November 5, 2013, the Ohio Supreme Court held that “this action does not satisfy the requirements for class certification pursuant to Civ. R. 23(B)(2), because the declaratory relief sought is at best only incidental to an award of monetary damages.” The Court also found that “the trial court abused its discretion in granting class certification pursuant to Civ. R. 23(B)(3), because a rigorous analysis of the evidence presented by parties demonstrates that individual questions present predominate over issues common to the class.” Quinn Emanuel subsequently convinced the Court to deny the plaintiff’s motion for reconsideration on December 24, 2013.

The Ohio Supreme Court’s decision constitutes a significant win for State Farm. The Court’s ruling not only decertifies the class in that specific case, but also will be generally helpful to the company in opposing other class actions in Ohio and elsewhere.