Law360, New York (July 26, 2016, 3:00 PM EDT) -- On Friday, July 15, the U.S. Court of Appeals for the Second Circuit reaffirmed that district courts have the power to decertify a class even after a jury verdict. In Mazzei v. The Money Store, No. 15-2054 (July 15, 2016), the Second Circuit held that a class of mortgage borrowers awarded $32 million by a jury was properly decertified by the district court before the entry of final judgment. The ruling serves as an important reminder that, even after class plaintiffs have met the threshold requirements of Rule 23 of the Federal Rules of Civil Procedure at the certification stage, they must still prove the merits of their claims on a classwide basis at trial. Thus, the decision reiterates that class action defendants have the opportunity to successfully challenge class certification even after trial....
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