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Sias v. Edge Communications, Inc.
Court of Civil Appeals of Oklahoma
8 P.3d 182 (2000)
Edge Communications, Inc. (Edge) (defendant) sold long-distance phone cards. The cards were disposable and sold in all 50 states. Edge advertised a rate of $.19 per minute but rounded minutes up and charged additional fees. The cards’ design and packaging did not disclose these additional charges. Michael Sias (plaintiff) brought a class action on behalf of all United States purchasers of Edge’s phone cards, alleging fraud and misrepresentations. Edge opposed Sias’s motion for class certification. Edge argued that the phone cards differed in design, denomination, and advertising, which differentiated the claims of individual class members. Edge also asserted that over four million cards had been sold and that the burden of managing a very large class would be massively expensive. Edge also argued that there were due-process problems associated with applying Oklahoma law to class members in other states. The trial court declined to certify Sias’s class because of the cost, administrative burden, and due-process problems with proceeding on a class-wide basis. The court held that the severe drawbacks of class-action litigation outweighed the very small recoveries class members stood to gain. The district court did not decide issues of commonality, typicality, or adequate representation but held only that class-action litigation was not the superior method of adjudication. Sias appealed, arguing the trial court had abused its discretion.
Rule of Law
Holding and Reasoning (Buettner, J.)
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