Brady v. AutoZone Stores, 960 F.3d 1172 (9th Cir. 2020)

Michael Brady sued AutoZone Stores for alleged violations of Washington State’s meal break laws.  After several years of litigation, the district court denied Brady’s motion for class certification; Brady then settled his individual claims with AutoZone.  Although the settlement agreement stated that it was “not intended to settle or resolve Brady’s Class Claims,” it did not provide that Brady would be entitled to any financial reward if the unresolved class claims were ultimately successful.  The Ninth Circuit dismissed as moot Brady’s appeal from the district court’s denial of class certification:  “A class representative must … retain a financial stake in the outcome of the class claims.  Absent such a stake, a class representative’s voluntary settlement of individual claims renders class claims moot.” See also Williams v. U.S. Bancorp Investments, Inc., 50 Cal. App. 5th 111 (2020) (collateral estoppel doctrine does not bar an absent class member in a putative class that was initially certified, but later decertified, from subsequently pursuing an identical class action)