Suchanek v. Sturm Foods, Inc.

Dist. Ct. erred in denying plaintiff’s motion to certify class action in four consolidated consumer protection lawsuits that essentially alleged that defendant used deceptive packaging of its single-serving coffee pods used in Keurig coffeemakers that, according to plaintiffs, misled consumers into believing that pod contained high quality ground coffee beans, rather than instant coffee that pod actually contained. Dist. Ct. failed to recognize potential common question as to all putative class members, i.e., whether defendant’s packaging was likely to mislead reasonable consumer as to contents of pod. Moreover, Dist. Ct.'s concern that each class member’s claim might require individualized inquiry on causation question was not valid reason for denying certification request since: (1) every consumer fraud case involves individualized elements of reliance or causation; and (2) class action would be appropriate in cases where damages for class members could be susceptible to measurement across entire class. Accordingly, plaintiffs were entitled to new consideration of class action issue.