Heaven v. Trust Company Bank
United States Court of Appeals for the Eleventh Circuit
118 F.3d 735 (11th Cir. 1997)
Heaven (plaintiff) sued Trust Company Bank (Sun Trust) (defendant), alleging it failed to meet the Consumer Leasing Act's strict disclosure requirements when she leased a car from Sun Trust, and moved to certify a class of similarly situated lessees. Sun Trust counterclaimed against class members, alleging some had defaulted on their leases and made false statements in their lease applications — counterclaims Heaven did not dispute were compulsory. The district court denied class certification, and Heaven appealed.
Whether class certification is proper when pursuing the class's claims would expose individual class members to compulsory counterclaims whose potential liability could exceed what the class action itself would recover for them.