In re Monumental Life Ins. Co.

365 F.3d 408 (2004)

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In re Monumental Life Ins. Co.

United States Court of Appeals for the Fifth Circuit
365 F.3d 408 (2004)

Facts

Life-insurance policy owners, all of whom were Black (the policy owners) (plaintiffs), brought suit in federal district court against three life-insurance companies, alleging they engaged in acts of discrimination by charging higher premiums and selling substandard policies to Black individuals. Policyholders sought injunctive relief to prohibit further collection of discriminatory premiums, reformation of the discriminatory policies, and backpay or benefit underpayments to make up for past overcharges. Policy owners filed a motion for certification of a class under Federal Rule of Civil Procedure 23(b)(2) (Rule 23(b)(2)). The district court denied the motion, finding that the monetary relief sought predominated over the injunctive relief sought. Moreover, the court noted that many proposed class members, including those with lapsed policies, had voluntarily adjusted policies and that those who already had received death benefits would not receive any benefit from the injunctive relief sought. The policy owners appealed.

Rule of Law

Issue

Holding and Reasoning (Smith, J.)

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