Briseno v. ConAgra Foods, Inc.
United States Court of Appeals for the Ninth Circuit
844 F.3d 1121 (9th Cir. 2017)
Consumers led by Robert Briseno (plaintiffs) sued ConAgra Foods (defendant) claiming its cooking oil's "100% Natural" label was misleading because the oil contained genetically-modified ingredients; they sought to certify a class of everyone who purchased the oil within the statute of limitations. ConAgra opposed certification, arguing there was no administratively feasible way to reliably identify who actually belonged in the class since consumers rarely keep receipts for inexpensive purchases; the trial court certified the class anyway, holding it sufficient that membership was defined by an objective standard (purchasing the oil during a specified period), and ConAgra appealed.
Whether, in a class-action lawsuit, a plaintiff must demonstrate an administratively feasible method for identifying class members as a prerequisite to obtaining class certification.