Blair v. Equifax Check Services, Inc.
United States Court of Appeals for the Seventh Circuit
181 F.3d 832 (7th Cir. 1999)
Equifax Check Services, Inc. (Equifax) (defendant), a check-verification service, had a practice of reserving the right to refuse to verify future checks of customers who had written dishonored checks, unless the dishonored check and fees associated with that check had been paid. Equifax would inform customers of this practice through a letter. Beverly Blair (plaintiff) and Letressa Wilbon filed suit against Equifax, alleging that this practice violated the Fair Debt Collection Practices Act. They represented a class of shoppers who had attempted to collect a check at specific retailers and who had received the debt collection letter from Equifax (the Blair class). The class sought only statutory penalties. Another class action against Equifax (the Crawford class) was certified the same day as the Blair class. The Crawford class was much larger than the Blair class, and due to its subject matter, actually encompassed all the Blair plaintiffs. The Crawford class reached a settlement agreement with Equifax, under which the individual members of the class would not receive notice or the opportunity to opt out. The settlement also forbade the prosecution of any of the claims as a class action. Based upon this settlement, Equifax requested that the Blair class be decertified. The trial judge denied Equifax’s motion, and Equifax appealed pursuant to Rule 23(f), which had been promulgated by the United States Supreme Court the previous year.
Rule of Law
Holding and Reasoning (Easterbrook, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 170,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.