Officials: Easterbrook, Kirsch, and Lee, Circuit Judges.

Focus: Labor and Employment Law-Class Action Litigation-Illinois Minimum Wage Law

Three former satellite service technicians initiated a class action lawsuit against their employer, DirectSat, claiming violations of the Illinois Minimum Wage Law (IMWL) and the Fair Labor Standards Act (FLSA). They allege that DirectSat did not compensate them for work performed beyond forty hours per week. Initially, the district court certified a class of full-time technicians in Illinois, but later vacated this certification, instead approving a Rule 23(c)(4) issue class to address fifteen specific questions regarding DirectSat's liability.

In 2019, the case was reassigned to a different district judge. Prior to the trial, the district court decertified the Rule 23(c)(4) class. Although the plaintiffs settled their individual claims, they retained the right to appeal the decertification. The court determined that a class action was not the best method for resolving the plaintiffs' disputes, citing the differing amounts of time technicians spent on work-related tasks and the individualized nature of their piece-rate compensation system.

The 7th Circuit found that a party seeking certification of an issue class under Rule 23(c)(4) must demonstrate that common questions predominate for the specific issues to be certified, rather than the entire cause of action. However, the appellate court upheld the district court's decision to decertify the class, concluding that the individualized nature of the claims necessitated separate trials to determine liability and damages, making a class action unsuitable.