Devlin v. Scardelletti

536 U.S. 1 (2002)

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Devlin v. Scardelletti

United States Supreme Court
536 U.S. 1 (2002)

Facts

Robert Devlin (plaintiff) was a retired worker who was a beneficiary of a pension plan (defendant). A class-action lawsuit was filed to determine the plan beneficiaries’ rights regarding a change to the pension plan. A mandatory class of plan beneficiaries was certified under Federal Rule of Civil Procedure 23(b)(1), which meant that the beneficiaries could not opt out. The class was divided into subclasses for active and retired workers. Although Devlin was invited to be the class representative for the retired subclass, he declined. Two years into the case, the parties reached a proposed settlement, and Devlin then moved to formally intervene in the case. The district court denied Devlin’s motion to intervene as untimely. However, in his capacity as an unnamed class member, Devlin raised objections to the settlement at the settlement’s fairness hearing. After the hearing, the district court approved the settlement. Devlin filed an appeal, challenging the district court’s ruling approving the settlement and its ruling denying his motion to intervene in the case. The Fourth Circuit affirmed the ruling denying Devlin the right to intervene in the case. The Fourth Circuit then held that Devlin had no right to appeal the settlement because he was not a named class representative, a recognized intervenor, or any other type of official party to the settled action. The United States Supreme Court granted certiorari to resolve a split among the circuit courts about whether an unnamed class member must formally intervene in a class action before being allowed to appeal a settlement approval in that action.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

Dissent (Scalia, J.)

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