For more than a decade, United States District Courts have taken a stark approach to the need for appropriate class definitions and ascertainability in federal class actions. Mueller v. CBS, Inc., 200 F.R.D. 227, 233 (W.D. Pa. 2001) (a class definition cannot be “amorphous, vague or indeterminate.”); Adair v. Johnston, 221 F.R.D. 573, 577 (M.D. Ala. 2004) (“[F]or a party to represent a class, the class sought to be represented must be adequately defined and clearly ascertainable.”).
The United States Courts of Appeals have followed suit. Young v. Nationwide Mut. Ins. Co., 693 F.3d 532, 538 (6th … Continue Reading