The Fourth Circuit recently sent a strong statement reinforcing the “rigorous analysis” required by Rule 23 in damages class actions. The message was blunt: class certification orders “are not participation trophies that are handed out to everyone on the tee ball team.” State of Rhode Island Office of the General Treasurer v. The Boeing Co., 182 F.4th 422, 447 (4th Cir. 2026) (“Boeing”). Instead, under long-standing Supreme Court precedent, plaintiffs seeking certification of a damages class must offer a reliable method of proving class-wide damages that fits their ...
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