Saucillo v. Peck, Nos. 20-55119, 20-55159, 2022 U.S. App. LEXIS 3839 (9th Cir. Feb. 11, 2022)
Following Roes, 1-2 v. SFBSC Management, LLC (9th Cir. 2019) 944 F.3d 1035, this decision holds that when a class action settles before class certification, the district court may not apply a presumption of fairness to the settlement based on arms-length negotiation between experienced counsel. Instead, the court mus employ extra caution and more rigorous scrutiny in evaluating a pre-certification… Read More