Class Certification In Haddock — An Outlier?

Law360, New York (December 18, 2009, 11:30 AM EST) -- Plaintiffs’ motion for certification of a class under Rule 23(b)(2) was recently granted in Haddock v. Nationwide Financial Services Inc., 2009 WL 3762339 (D. Conn. 2009), a lawsuit alleging that defendant engages in certain revenue-sharing practices that violate ERISA.

A number of courts have certified classes in ERISA revenue-sharing cases directed against single plan sponsors, but this is the first grant of class certification in a case asserting claims directed against a financial service provider on behalf of all the plans it served.

In the only...
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