Will Supreme Court Punt On Circuit Split Over Article III Standing In Class Actions?

On April 29, 2025, the Supreme Court heard argument on an issue that has divided the circuits: "Whether a federal court may certify a class action pursuant to Federal Rule of Civil Procedure 23(b)(3) when some members of the proposed class lack any Article III injury?" The case is Laboratory Corporation of America Holdings, dba Labcorp v. Luke Davis, et al., Case No. 22-55873, and the court's decision could have a significant impact on class action litigation across the country. But the justices' questions at oral argument highlighted a procedural wrinkle that could prevent the court from resolving this hotly contested issue.

The named plaintiffs in LabCorp are legally blind individuals who allege that they are unable to use the self-service check-in kiosks installed at LabCorp's patient service centers. Based on these allegations, the plaintiffs assert claims for damages under the Americans with Disabilities Act and California's Unruh Act.