Shining A Light On The Importance Of Article III Standing In Class Settlements

KEY TAKEAWAY: 

In Smith v.  Miorelli, the United States Court of Appeals for the Eleventh Circuit reminded litigants of the importance of Article III standing, even where the parties agree to settle. Federal courts do not have authority to adjudicate a claim or to award a specific form of relief unless the plaintiff first satisfies this jurisdictional requirement. 

On February 26, 2024, the Eleventh Circuit invalidated a settlement agreement reached by the parties to resolve a trio of class action lawsuits against major sunglasses manufacturer, Costa Del Mar, Inc.¹ Without reaching any other arguments raised by the unnamed class-member objectors on appeal, the court voided the settlement because the named plaintiffs sought—but did not establish Article III standing entitling them to—injunctive relief.²