On August 12, 2011, the Sixth Circuit released its decision in Pipefitters Local 636 Insurance Fund, et al. v. Blue Cross Blue Shield of Michigan, 654 F.3d 618 (6th Cir. 2011) (“Pipefitters”). On an interlocutory appeal, the Court reversed an order certifying a class of hundreds of multi-employer trust funds asserting fiduciary claims arising under the Employee Retirement Income Security Act (“ERISA”).
The decision is significant (1) for its application of the “rigorous analysis” standard and its directive that courts analyze the substantive requirements of each claim before certifying a class; (2) its finding that class treatment is not superior to other methods of adjudication where individualized inquiries are required to determine threshold issues; and (3) its decision to reverse the case rather to remand for further consideration by the trial court.
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