Background
Plaintiffs Lauren Spurlock, Heather Smith, and Shawn Zmudzinski, who suffer from opioid use disorder, filed a class action lawsuit under Section nineteen eighty-three of Title forty-two of the United States Code. They alleged that Wexford Health Sources, Inc., a private medical contractor for prisons and jails, maintained a policy of excluding screening and treatment for opioid use disorder from its comprehensive medical services. The plaintiffs sought injunctive relief to require Wexford to provide such treatment and damages for past injuries caused by forcing incarcerated individuals to undergo withdrawal. The district court certified two classes: one for injunctive relief and one for damages. Wexford appealed the certification order.
The court’s reasoning
The court addressed the standing requirement for the Injunctive Relief Class first. Because standing was raised for the first time on appeal and requires fact-specific findings regarding the likelihood of the plaintiffs being reincarcerated, the court remanded this issue to the district court. The court found that the district court did not abuse its discretion in certifying the Damages Class. The court concluded that the class was ascertainable based on Wexford’s records, that common questions of law and fact predominated, and that the named plaintiffs adequately represented the class. The court clarified that while every class member must have standing to recover damages, only the named plaintiffs need to demonstrate standing at the class certification stage.
We therefore remand to the district court to consider whether the Named Plaintiffs possess standing to represent the Injunctive Relief Class.
What it means going forward
The decision allows the damages class action to proceed while requiring a lower court hearing to resolve the threshold question of whether the plaintiffs can seek an injunction for future treatment. It reinforces that class certification does not require individualized standing determinations for all potential class members.
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