Concert Plantation, LLC v. Dorso
The Second District affirmed certification of a class of roughly 750 former equity members of a golf and country club seeking refunds of membership fees allegedly impaired by a 2016 bylaw amendment. The majority held that the unresolved common question of when refund rights vested predominated, that affirmative defenses peculiar to individual members do not defeat predominance, and that variation in damages is not a basis to deny certification. A lengthy dissent argued typicality, adequacy, and predominance failed and that subclasses relied on to cure predominance must be defined and certified at the time of class certification.
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