Hanlon v. Chrysler Corporation
United States Court of Appeals for the Ninth Circuit
150 F.3d 1011 (1998)
After NHTSA investigated rear-latch problems in Chrysler minivans, multiple class actions were consolidated, and Hanlon and other named plaintiffs (plaintiffs), representing all 50 states and affected models, quickly reached a latch-replacement settlement with Chrysler Corporation (defendant). The court certified a nationwide class, notified 4.3 million members (971 of whom opted out), and enjoined a Georgia state-court class member (Kempton) from purporting to opt out an entire subclass on his own. After NHTSA closed its investigation as satisfied with Chrysler's remedy, the court held three fairness hearings and approved the settlement and $5 million in lodestar-based attorneys' fees. Objectors appealed both the certification and the settlement/fee approval.
Whether a settlement class is properly certified where it satisfies heightened scrutiny of numerosity, commonality, typicality, and adequate representation, common issues predominate, and class treatment is superior to individual suits, and whether approval of the class settlement and attorneys' fees was appropriate given the adequacy of notice, the court's consideration of fairness factors, and use of the lodestar method.