Sixth Circuit: Terry Martin v. Behr Dayton Thermal Prods.

As requiring a preliminary determination of predominance would unduly narrow the remedy, courts can determine specific issues for a class action without requiring that those issues must predominate within a putative individual action.  Here, the issue classes predominate and are best addressed as a class.  Circuit split flagged.

Any Seventh Amendment harms from the Special Master process are presently speculative.

http://www.opn.ca6.uscourts.gov/opinions.pdf/18a0139p-06.pdf