Robidoux v. Celani
United States Court of Appeals for the Second Circuit
987 F.2d 931 (1993)
The Vermont Department of Social Welfare (Department) (defendant) repeatedly missed the federally required 30-day deadline for deciding food-stamp, ANFC, and fuel-assistance applications, and Julie Robidoux and others (plaintiffs) sued under Section 1983, seeking to represent a class of everyone whose applications were similarly delayed. Official records showed 22 to 133 applicants per month affected by delays in food stamps or ANFC, though the plaintiffs lacked similar records for the seasonal Fuel Assistance Program. The district court denied class certification, finding the plaintiffs hadn't shown joinder was 'impossible,' hadn't shown typicality because they lacked personal fuel-assistance claims, and finding the claims moot since all three had since received retroactive benefits.
Whether a proposed class satisfies the requirements of numerosity and typicality under Federal Rule of Civil Procedure 23(a) if joinder would be impracticable given the size and circumstances of the class and the scope of the class is limited to the type of claims sought by the class representatives.