One Size Fits None: Sixth Circuit Demands State-by-State Analysis In Auto Defect Class Actions

Summary

The U.S. Court of Appeals for the Sixth Circuit, in a full en banc decision, raised the pleading and proof standards for plaintiffs seeking to certify multistate automotive defect class actions. The court's June 27, 2025, ruling in Speerly v. General Motors, LLC, rejected the district court's certification of 26 statewide subclasses of nearly 800,000 vehicle owners, demanding a more rigorous, state-by-state and claim-by-claim analysis. For automotive manufacturers, this decision provides another effective precedent to challenge the certification of sprawling, multistate class actions.

The Upshot

• Generalized Defects Are Insufficient: The Sixth Circuit held that plaintiffs cannot simply allege a common "defect" to satisfy the commonality requirement. Instead, they must prove, with evidence, how the alleged defect satisfies the specific legal elements of each state-law claim being pursued.