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IN RE: FORD MOTOR COMPANY,
Petitioner.
___________________________________________

PAUL WEIDMAN, et al.,
Plaintiffs-Respondents,
v.
FORD MOTOR COMPANY,
Defendant-Petitioner.
   No. 22-0109
On Petition for Permission to Appeal.
United States District Court for the Eastern District of Michigan at Detroit;
No. 2:18-cv-12719—Gershwin A. Drain, District Judge.
Decided and Filed: November 16, 2023
Before: BOGGS, THAPAR, and READLER, Circuit Judges.


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OPINION
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PER CURIAM. By enabling enormous aggregation of claims and parties, class actions represent a significant departure from “our constitutional tradition of individual litigation.” Brown v. Electrolux Home Prods., Inc., 817 F.3d 1225, 1233 (11th Cir. 2016). It’s easy to understand why class actions are the exception, not the rule; exponential aggregation of claims and parties magnifies the stakes of litigation and can thus have massive ramifications for plaintiffs and defendants alike. See Blair v. Equifax Check Servs., Inc., 181 F.3d 832, 834 (7th Cir. 1999) (Easterbrook, J.) (“[A] grant of class status can propel the stakes of a case into the stratosphere.”). To ensure appropriate use of this potent litigation device, Federal Rule of Civil Procedure 23 serves as a gatekeeper to class certification. Far more than “a mere pleading standard,” Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350 (2011), the Rule erects four threshold safeguards: numerosity, commonality, typicality, and adequacy. Fed. R. Civ. P. 23(a). Satisfying the Rule requires a named plaintiff to offer “[s]ignificant” evidentiary proof that he can meet all four of those criteria, where they are contested. Doster v. Kendall, 54 F.4th 398, 432 (6th Cir. 2022) (quoting Wal-Mart, 564 U.S. at 353); see also Comcast Corp. v. Behrend, 569 U.S. 27, 33 (2013). As for the district court, it should not certify a class unless its “rigorous analysis” shows that not one or two, but all four Rule 23(a) prerequisites are met. Davis v. Cintas Corp., 717 F.3d 476, 484 (6th Cir. 2013) (quoting Gen. Tel. Co. of the Sw. v. Falcon, 457 U.S. 147, 161 (1982)).

The district court in this case certified statewide classes to resolve three issues relating to a purported brake defect in Ford F-150 pickup trucks. For the most part, the district court thoughtfully considered the issues presented in concurrent motions for summary judgment and class certification. But Rule 23 requires precision across the board. And the district court’s cursory treatment of commonality, one of the four necessary class action ingredients, failed to meet Rule 23’s stringent requirements. See Fed. R. Civ. P. 23(a)(2). For that reason, we grant Ford’s Rule 23(f) petition for interlocutory review, vacate the class certification order, and remand for more searching consideration. See In re Tivity Health, Inc., No. 22-0502, 2022 WL 17243323, at *2 (6th Cir. Nov. 21, 2022).