Pickett v. Holland America Line-Westours, Inc.

145 Wash. 2d 178 (2001) · Washington Supreme Court · November 29, 2001

Summary

The Washington Supreme Court reviewed approval of a class-action settlement involving Holland America’s collection and representation of cruise “port charges and taxes.” The court held that appellate review should focus on whether the settlement was fair, adequate, and reasonable, rather than deciding the merits of the underlying class-certification ruling. Applying an abuse-of-discretion standard, the court concluded that the settlement should be approved.

Holdings

  1. When reviewing approval of a class-action settlement, an appellate court should confine its review to whether the settlement is fair, adequate, and reasonable and should not decide the merits of the trial court's earlier denial of class certification in the first instance.
  2. A proposed class-action settlement may be approved when the trial court determines that it is fair, adequate, and reasonable, and the approval is reviewed for abuse of discretion.

Questions Presented

  1. Whether the Court of Appeals erred by deciding the merits of the trial court's denial of class certification when reviewing approval of a class-action settlement.
  2. Whether the settlement was fair, adequate, and reasonable under Washington Civil Rule 23(e).
  3. What standard governs appellate review of a trial court's approval of a class-action settlement.

Disposition

reversed

Cases Cited (10)

  • Pickett v. Holland America Line-Westours, Inc., 101 Wn. App. 901, 922, 6 P.3d 63 (2000)(reversed)
  • Officers for Justice v. Civil Service Commission, 688 F.2d 615, 623-25 (9th Cir. 1982)(followed)
  • American Pipe & Construction Co. v. Utah, 414 U.S. 538, 550-51, 94 S. Ct. 756, 38 L. Ed. 2d 713 (1974)(explained)
  • Anderson v. Unisys Corp., 47 F.3d 302, 308 (8th Cir. 1995)(followed)
  • Phillips Petroleum Co. v. Shutts, 472 U.S. 797, 820-22, 105 S. Ct. 2965, 86 L. Ed. 2d 628 (1985)(followed)
  • Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. Co., 105 Wn.2d 778, 793, 719 P.2d 531 (1986)(followed)
  • Nuttall v. Dowell, 31 Wn. App. 98, 111, 639 P.2d 832 (1982)(discussed)
  • Mason v. Mortgage America, Inc., 114 Wn.2d 842, 792 P.2d 142 (1990)(distinguished)
  • City of Detroit v. Grinnell Corp., 495 F.2d 448, 454-55 (2d Cir. 1974)(followed)
  • Reed v. General Motors Corp., 703 F.2d 170, 175 (5th Cir. 1983)(followed)

Cited In (0)

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