Eighth Circuit: Jim Sciaroni v. Target Corporation

Class appropriately certified despite court's mistaken finding that class members without present injury would be entitled to a pro rata share of the remainder of the fund.

Class appropriately certified despite potential inter-class conflicts over later-arising harms from the data breach, since all class members suffered the same injury at the same time.

29% Fee award can appropriately be based on a total that includes administrative costs; fees not substantively unreasonable.

Settlement not unfair, despite alleged subtle signs of collusion.

http://media.ca8.uscourts.gov/opndir/18/06/153909P.pdf