Martin v. Reid

Dist. Ct. did not abuse its discretion in approving settlement of class action against manufacturer of hair-smoothing product that allegedly destroyed users’ hair and burned their scalps, where said settlement created three funds awarding consumers either: (1) sum up to $40 per person for cost of hair kit depending on whether consumer had receipt; (2) sum up to $800 per person if consumer had incurred hairdresser costs or certain medical bills arising out of use of hair kit; or (3) sum up to $25,000 per person, if consumer incurred significant bodily injuries. While class member objected to said settlement by arguing that $10,250,000 that was set aside for class compensation was inadequate and lacked reasonably accurate quantitative analysis of benefits provided, as compared with risks and benefits of litigation, Dist. Ct. could properly overrule instant objection, where objector could only speculate that settlement amount was inadequate or that many unanticipated claims will be filed. Fact that individual class members had different injuries that were potentially calculated under different state laws did not require different result because settlement agreement contained choice of law clause specifying that injuries were to be calculated under Illinois law.