DirectSat Workers’ Wage, Hour Class Action Properly Decertified

Decertification of a class of satellite technicians in a wage suit against DirectSat USA LLC was proper because a class action wasn’t the best device for resolving the case, the Seventh Circuit held.

The district court reached the right result despite using the wrong test to decertify the class, Judge John Z. Lee wrote Thursday for the US Court of Appeals for the Seventh Circuit.

There’s a circuit split over creating issues-only classes under Rule 23(c)(4), the Seventh Circuit said. The Fifth Circuit limits Rule 23(c)(4) classes to cases where the cause of action, taken as a whole, satisfies Rule ...