August 13, 2019 Article

Personal Jurisdiction over Unnamed Class Members

This year, the Fifth, Seventh, and D.C. Circuits are set to determine whether Bristol-Myers Squibb applies to class actions.

By Joan R. Camagong

While the Supreme Court’s opinion in Bristol-Myers Squibb Co. v. Superior Court (BMS), 137 S. Ct. 1773 (2017), provides clear guidance for mass tort actions involving nonresident plaintiffs, district courts are increasingly divided as to its application to unnamed, nonresident plaintiffs in class actions. 

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