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Attorney: Chelsea Pieroni

May 13, 2025 Chelsea Pieroni
Posted in  Class Certification Standing

Third Time’s Not a Charm: Recent Fourth Circuit Decision Affirming Denial of Class Certification Reinforces Certain Tenets of Rule 23 Analysis

In Mr. Dee’s Inc. v. Inmar, Inc., 127 F.4th 925 (4th Cir. 2025), the Fourth Circuit affirmed a decision by Judge William L. Osteen, Jr. of the Middle District of North Carolina denying, for the third time, plaintiffs’ attempt to certify a class of coupon manufacturers. It is not only […]

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January 7, 2025 Kyle A. Medin Chelsea Pieroni

Voluntary Dismissals of Putative Class Actions Under Federal Rule 23(e): Permission, or Forgiveness?

Does a trial court have to approve a voluntary dismissal of a putative class action before the case gets to class certification? While the precise answer remains uncertain, the Fourth Circuit, North Carolina courts, and other jurisdictions have made room for a Rule 23(e)-adjacent—or, Rule 23(e) “light”—approach for handling voluntary, […]

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December 13, 2023 Chelsea Pieroni Christopher Rhodes Jr.
Posted in  Class Action Basics

The Eleventh Circuit Speaks Firmly on Calculating Attorneys’ Fees: Look to the Local Community and Mind Your Multipliers

In a previous post, we covered Sos v. State Farm Mutual Automobile Insurance and analyzed the pick-off exception under Eleventh and Fourth Circuit case law. No. 21-11769 (11th Cir. 2023).  Sos involved another issue of significance: the calculation of attorneys’ fees, which is the subject of this blog post. Click […]

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November 30, 2023 Chelsea Pieroni Christopher Rhodes Jr.
Posted in  Class Action Basics

That Don’t Impress Me Much! Recent Eleventh Circuit Decision Weighs in on Whether Paying Off a Class Can Moot a Class Action, with Fourth Circuit Law Remaining Inconclusive.

While perhaps rare, directly paying off a named plaintiff and putative class members before class certification is one tactic for potentially nipping a class action in the bud.  It can be effective when both parties are willing to play ball and negotiate a settlement. However, a recent Eleventh Circuit decision […]

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