The Supreme Court's decision last term in Zahn v. International Paper Co. was greeted in the news media with prophecies of doom for class actions brought in federal court. Though the media's concern was earnest, upon closer inspection, Zahn does not nearly have such a virulent effect. There is little doubt, however, that Zahn will be a serious hurdle to many class action litigants in federal court.
Richard P. Berg,
Zahn v. International Paper: Taking the Action Out of Class Action, Or Can Zahn Be Avoided?,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol12/iss1/10