Class Action Claims Were Moot After Class Representative Settled His Individual Claims

Brady v. AutoZone Stores, 960 F.3d 1172 (9^th Cir. 2020)

Michael Brady sued AutoZone Stores for alleged violations of Washington State's meal break laws. After several years of litigation, the district court denied Brady's motion for class certification; Brady then settled his individual claims with AutoZone. Although the settlement agreement stated that it was "not intended to settle or resolve Brady's Class Claims," it did not provide that Brady would be entitled to any financial reward if the unresolved class claims were ultimately successful. The Ninth Circuit dismissed as moot Brady's appeal from the district court's denial of class certification: "A class representative must ... retain a financial stake in the outcome of the class claims. Absent such a stake, a class representative's voluntary settlement of individual claims renders class claims moot." See also Williams v. U.S. Bancorp Investments, Inc., 50 Cal. App. 5^th 111 (2020) (collateral estoppel