Heaven v Trust Company Bank

1997

Venue: 11th Cir.

Facts: Heaven leases a Ford Taurus. Sun Trust allegedly overcharged as part of their preprinted form leases.

Posture: Motion for class certification. Sun-Trust brings (compulsory) counterclaims against class members who have made false statements in their lease applications or defaulted on the agreements. District court denies certification of the class. Appeal.

Issue: Did the district court abuse its discretion in denying the motion to certify the class?

Holding: No.

Rule: First, abuse of discretion is hard to overcome. But also, these counterclaims mean that different class members will have different (and maybe contrary) interests. So the district court was right.

Reasoning:

Dicta: