Seventh Circuit Affirms Decertification Of DirectSat's Wage And Hour Class Action

Duane Morris Takeaways: On October 3, 2024, the Seventh Circuit upheld the decertification of a class of satellite technicians in a wage and hour suit against DirectSat USA LLC ("DirectSat") on the grounds that a class action was not the best method of resolving the lawsuit. The ruling in Jacks v. Directsat USA, LLC, Case No. 23-3166, 2024 U.S. App. LEXIS 25099 (7th Cir. Oct. 3, 2024), is significant, as it represents the first time the Seventh Circuit has taken a definitive position on resolving "issues class actions" under Rule 23(c)(4), a topic that is currently the subject of a circuit split. Although the Seventh Circuit ultimately agreed with the majority approach adopted by the Second, Third, Fourth, Sixth and Ninth Circuits – that permits certification as long as common questions predominate in resolving the individual issues to be certified – it also clarified that district courts should look at the relationship any certified issues have to the dispute as