Kartman v. State Farm Mutual Automobile Ins. Co.

Dist. Ct. erred in certifying class action for injunctive relief under Rule 23(b)(2) in action alleging that defendant-insurance company breached contractual obligation by consistently underpaying plaintiffs-policyholders who submitted claims for hail damage done to their roofs. While Dist. Ct. concluded that class claim for injunctive relief could proceed to determine whether defendant should be required to re-inspect plaintiffs' roofs pursuant to uniform and objective standard, instant case was not appropriate for class certification under Rule 23(b)(2) where plaintiffs' remedy in instant case was only for monetary damages, and where there was no contract or tort-based duty requiring defendant to use particular standard for assessing hail damage. Moreover, requested injunction as envisioned by plaintiffs was not final remedy for purposes of Rule 23(b)(2) since class-wide roof re-inspection would only lay evidentiary foundation for subsequent individual determinations of liability.