By: Derek Hawkins//March 6, 2022
7th Circuit Court of Appeals
Case Name: Andrea Santiago v. City of Chicago
Case No.: 20-3522
Officials: FLAUM, KANNE, and SCUDDER, Circuit Judges.
Focus: Class Action – Certification
Andrea Santiago, a severely disabled Chicago resident, would leave her van parked on the street in front of her home for extended periods of time. In 2018, pursuant to the Chicago Municipal Code, her van was towed, impounded, and disposed of. She sued the City of Chicago on her own behalf and on behalf of others similarly situated, challenging the constitutionality of various aspects of the City’s scheme, among other things. She moved the district court to certify her suit as a class action, and the district court granted her motion in part. However, because the class certification order does not fully demonstrate the “rigorous analysis” required by Rule 23, an approval, at this point, constituted an abuse of discretion. We therefore vacate and remand for further consideration.
Vacated and remanded
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Derek A Hawkins is Corporate Counsel, at Salesforce.[/box]