Docket 24-304
Laboratory Corp. of America Holdings v. Davis
DecidedJun 5, 2025
Per Curiamdecision
Source: CourtListener.
Supreme Court dismisses case on whether class-action suits can include uninjured members
Impact3/10
What it does
The Court dismissed the case as "improvidently granted," meaning it decided — without explanation — that it should not have agreed to hear the case in the first place. No ruling was issued on the underlying legal question. The Ninth Circuit's decision below, which allowed class certification even when a class includes more than a small number of uninjured members, therefore remains in effect within that circuit.
Who benefits
Plaintiffs in class-action lawsuits filed in the Ninth Circuit (which covers nine western states), who can continue to pursue class certification even when some class members may not have been personally harmed.
Who is affected
Businesses facing class-action lawsuits in the Ninth Circuit, who remain subject to a legal standard that allows large classes — potentially including uninjured members — to be certified against them.
Practical impact
Because the Court dismissed the case without ruling, the Ninth Circuit's standard — permitting class certification even when more than a small number of class members may be uninjured — remains the law in the nine states of the Ninth Circuit. A circuit split on this question remains unresolved, meaning different rules continue to apply in different parts of the country. Businesses facing class-action suits in the Ninth Circuit cannot yet rely on a Supreme Court ruling to challenge overbroad class definitions on this ground.
Majority reasoning
The Per Curiam majority issued a single sentence: the writ of certiorari (the Court's agreement to hear the case) is dismissed as improvidently granted. No reasoning was provided. The Court did not rule on whether the case was moot, and it did not rule on the underlying class-action question. The dismissal leaves the Ninth Circuit's ruling in place without the Supreme Court endorsing or rejecting it.
Dissent reasoning
Justice Kavanaugh argued the Court should have decided the case rather than walking away from it. He wrote that the plaintiffs' argument that the case was moot — meaning no longer a live legal dispute — was not convincing, and he explained in detail why Labcorp had properly appealed the correct court order at each stage. On the merits, he argued that Rule 23 requires that common legal questions must be the dominant issues in a damages class action, and that a class mixing injured and uninjured members cannot satisfy that requirement because uninjured members, by definition, do not share the same injury as the rest of the class. He warned that allowing overbroad classes creates pressure on businesses to settle even weak cases to avoid potentially catastrophic liability — costs he said are ultimately passed on to consumers, retirement account holders, and workers.
Constitutional question
May a federal court certify a damages class under Federal Rule of Civil Procedure 23 when the class includes both people who were injured and people who were not injured?