In Illinois, defendants can moot a class action case by making an individual settlement offer to a named plaintiff. Fortunately for class members, plaintiffs have ways to preempt this move. Here's the state of the law.
On November 30, 2006, the Illinois Supreme Court reversed the decisions of the Illinois Appellate Court, Fifth District, and the Circuit Court of Perry County, both of which improperly certified a class of plaintiffs.
The Illinois Supreme Court barred plaintiffs' class action claim and overturned a $10-plus billion award against Philip Morris. But experts doubt the case will have much precedential power outside Illinois.