S1983, Prisons, Class Actions, FRCP
Prisoner claims asserting deliberate indifference under S1983 were improperly certified into a class, since although they shared an essential claim, the question of commonality implies a consideration of redressibility, and the relief sought in individual claims did not always support the remedy sought on behalf of the class as a whole.
Motion for relief from final judgment was inappropriate to challenge denial of certification -- an amended motion to certify the class remained available, appealable if a subsequent decision of the court materially alters the position of the class.
Melvin Phillips v. Sheriff of Cook County
