Seventh Circuit Vacates Class Certifications in a Student v. University COVID Case

A district court certified two classes of students, one for tuition and one for fees, in connection with Bradley University’s move to remote classes in Spring 2020.  One week of classes was cancelled and not rescheduled, producing a fourteen-week semester rather than the fifteen-week semester promised in Bradley’s 2019-20 Academic Catalog.  The catalog also stated, “This catalog serves as a contract between a student and Bradley University.” 

People!  Why?

That’s really all I have to say about the case.  In Eddlemon v. Bradley University, the Seventh Circuit reversed both class certifications, but for civ. pro. reasons.  Precedent requires that a court undertake “rigorous analysis” to ascertain all of the requirements listed under F.R.C.P. 23 are satisfied before it certifies a class.  Here, the district court relied on the allegations of the complaint and cursory reasoning or conclusory statements with respect to commonality and predominance, so the case is remanded so that the district court can try again.