Huyer v. Van de Voorde

Summary

The Eighth Circuit dismissed Rhadiante Van de Voorde’s appeal of a class-action settlement involving Wells Fargo’s property-inspection fees. The court held that she lacked standing to challenge settlement provisions requiring post-sale class members to submit proofs of claim because she was classified as an active or paid-in-full member and suffered no injury from those provisions. A concurrence characterized the defect as prudential rather than constitutional standing.

Holdings

1. An unnamed class member's objection to approval of a class action settlement does not automatically confer Article III standing to appeal; the objector must independently satisfy Article III standing requirements.
2. Van de Voorde lacked standing to appeal the settlement provisions concerning post-sale class members because she was an active or paid-in-full class member, was not injured by the proof-of-claim requirement, and would not benefit from eliminating it.

Questions Presented

1. Whether an unnamed class member's objection to a settlement automatically establishes Article III standing to appeal its approval.
2. Whether Van de Voorde had standing to challenge settlement provisions affecting only post-sale class members when she was an active or paid-in-full class member and would not benefit from the requested changes.

Disposition

dismissed