State Farm Can’t ‘Pick Off’ Class Suit Over Car Taxes, Fees

State Farm Mutual Automobile Insurance Co. can’t avoid a class action over its failure to pay sales taxes and title transfer fees by paying off the named plaintiff’s claim, the Eleventh Circuit said.

State Farm said that the payment to Anthony Sos before the class was certified mooted the suit, but the opinion by Judge Andrew L. Brasher said that the class action was saved by the relation-back doctrine. The doctrine recognizes that a plaintiff whose claims are satisfied before class certification can continue pursuing the class action in certain circumstances because the claims relate back to the filing of ...