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ARTICLE · 02 NOVEMBER 2026

Northern District Of Illinois Denies Class Certification In No Poach Case

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A federal court denied class certification in an antitrust case where healthcare employees alleged wage suppression through no-poach agreements, finding that plaintiffs failed to demonstrate common proof of injury across a diverse workforce. The decision highlights critical evidentiary requirements for establishing predominance in employment antitrust class actions, particularly regarding expert testimony on wage suppression and compensation system uniformity.

United StatesAntitrust/Competition Law
On June 10, 2026, Judge Sunil R. Harjani of the United States District Court for the Northern District of Illinois denied a motion for class certification from former healthcare employees claiming that their wages were suppressed by alleged no-poach agreements. The Court concluded that plaintiffs failed to demonstrate that common questions would predominate over individualized questions and failed to show predominance of common issues to assess antitrust impact and damages. In re Outpatient Medical Center Employee Antitrust Litigation, No. 1:21-cv-00305 (N.D. Ill. Jun. 10, 2026).

Plaintiffs sought to represent a putative class of more than 6,000 senior-level employees from the three defendant outpatient medical centers. Plaintiffs alleged that, starting in 2008, defendants allegedly reached agreements not to recruit senior-level employees from each other. These “no poach” agreements allegedly barred defendants from recruiting director-level and above positions from each other and

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