Scott v. Dart

Plaintiffs filed a class action lawsuit alleging that Cook County provided inadequate dental care to pretrial detainees in violation of the Fourteenth Amendment. The Seventh Circuit court refused to certify the class and plaintiff appealed, despite the named plaintiff having voluntarily settled his claim. The circuit court vacated and remanded, concluding that the district court abused its discretion in denying class certification finding that if it followed the district court’s rationale then a class of detainees would never be able to certify as a class because medical care, by its nature, is individualized. (KIRSCH and JACKSON-AKIWUMI, concurring)