Class action lawsuits are procedurally complex matters that pose unique challenges for the defense. Understanding the statutory requirements for class actions is essential to the development of an effective defense strategy, including whether opposing class certification is in the defendant’s best interest.

In a recently filed lawsuit, Plaintiff Ken Angelini alleges that Defendant TTI Outdoor Power Equipment, Inc., owner and operator of the brand RYOBI, manufactured, imported, distributed, and sold defective electric pressure washers that can explode and injure users. Specifically, the lawsuit alleges that the pressure washer can overheat, resulting in an explosion forcefully ejecting parts of the pressure washer, therefore posing a risk of serious injury to users and bystanders.[i]  The complaint alleges that TTI received 135 complaints about pressure washers overheating, including 41 reports of explosions resulting in 32 injuries.[ii]  Plaintiff is suing for violations of California consumer laws and breach of implied warranty, and seeks to represent anyone who purchased a RYOBI pressure washer in 26 states during the statute of limitations.[iii]

Class action lawsuits may be initiated in either federal or state courts. Rule 23 of the Federal Rules of Civil Procedure governs actions like Angelini v. TTI Power Equipment, Inc. The rule requires the following findings for maintenance of a class action: (1) numerosity of claims rendering joinder of all members impractical; (2) that there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties to be typical of the class; and (4) that the representative parties will fairly protect the interests of the class.[iv]

If the foregoing four elements are satisfied, a class action may proceed if the court also determines that: (1) prosecuting individual actions will result in inconsistent or varying adjudications with respect to the class or incompatible standards for the defendant or would be dispositive to and impair the interests of other members who are not parties to the individual adjudications; (2) the party opposing the class has refused to act on grounds applying generally to the class, necessitating injunctive relief to the class as a whole; or (3) class action is superior to individual adjudication because questions of law or fact common to the class predominate over those affecting individual members.[v]  “At an early practicable time” after a Plaintiff sues as a class representative, the court must determine whether to certify the class, triggering special notice requirements and special implications for dismissals, settlements, and judgments.[vi]

In California, the operative statute is Code of Civil Procedure Section 382.  It states, in part, “…when the question is one of a common or general interest, of many persons, or when the parties are numerous, and it is impractical to bring them all before the court, one or more may sue or defend for the benefit of all.”  Additionally, in California, “[t]he party advocating class treatment must demonstrate the existence of an ascertainable and sufficiently numerous class, a well-defined community of interest, and substantial benefits from certification that render proceeding as a class superior to the alternatives.”[vii]

For the defendant in a class action lawsuit, a prompt assessment of whether the proposed class meets the requirements for certification is essential to ensure a successful defense strategy.  The pitfalls of class certification include massive financial liability due to aggregated claims, the cost of defending a legally complex lawsuit, and negative publicity. Benefits of class action for defendants include judicial efficiency, uniformity of judgments, and shared expenses.  Notably, a February 2010 report issued by the California Judicial Council, Administrative Office of the Courts, concluded that 89% of cases with class certification ended in settlement, while only 15% of cases without class certification ended in settlement.[viii]  Therefore, depending on the estimated liability exposure, class action certification may best protect the interests of the client.

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Sources

[i] Compl., Angelini v. TTI, No. 5:25 cv 02280 (C.D. Cal. Sept. 2, 2025).

[ii] Id.

[iii] Id.

[iv] Fed. R. Civ. P. 23(a)(1)-(4).

[v] Fed. R. Civ. P. 23(b)(1)-(3).

[vi] Fed R. Civ. P. 23(c), (e).

[vii] Brinker Rest. Corp. v. Superior Ct. 53 Cal. 4th 1004, 1020, 273 P.3d 513 (2012)..

[viii] Judicial Council of California, Administrative Office of the Courts, Class Certification in California: Second Interim Report from the Study of California Class Action Litigation (Feb. 2010), available at https://www.courts.ca.gov/reference