Class Action

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7^th Circuit Court of Appeals

Case Name: Quintin Scott v. Thomas Dart

Case No.: 23-1312

Officials: Wood, Kirsch, and Jackson-Akiwumi, Circuit Judges.

Focus: Class Action

Scott, a former pretrial detainee at the Cook County Jail, initiated a class action lawsuit against Cook County and its sheriff. Scott alleged that the county failed to provide adequate dental care to him and other pretrial detainees, thereby violating their rights under the Fourteenth Amendment. Initially, the district court declined to certify the class. However, Scott settled his individual claim while reserving his right to challenge the class certification ruling and to seek an incentive award for his role as the lead plaintiff.

Cook County argued that Scott lacked standing to pursue the class aspects of the case, asserting that he no longer had a stake in the litigation and that courts were prohibited from granting incentive awards. The Seventh Circuit disagreed, affirming Scott’s standing and recognizing the validity of incentive awards. Additionally, the court determined that the district court had erred in denying class certification by misapplying precedent and applying an excessively strict standard.

Consequently, the Court of Appeals vacated the district court’s order and remanded the case for further proceedings. It emphasized that the district court had the discretion to revise the class definition to address any overbreadth concerns. Furthermore, the court highlighted that the district court had not assessed whether the proposed class met the prerequisites of numerosity and adequacy of representation, which must be fulfilled for class certification.

Vacated and remanded.

Decided 04/29/24

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