The U.S. Supreme Court on Thursday dismissed a high-profile class-action case, declining to decide whether federal courts can certify classes that include both injured and uninjured members.

In Laboratory Corporation of America Holdings v. Davis, the court had initially agreed to consider whether a federal court could approve a damages class under Federal Rule of Civil Procedure 23 when the group comprises both injured and non-injured individuals.

Federal Rule of Civil Procedure 23 governs class-action lawsuits in federal courts, outlining the requirements for certifying a group of plaintiffs as a class, including commonality of legal or factual issues, adequacy of representation, and predominance of common questions.

However, in a brief per curiam order, the justices dismissed the writ of certiorari as "improvidently granted," effectively sidestepping the significant legal question involved. The unusual dismissal came after oral arguments in April, reflecting uncertainty about whether the justices would rule on the merits or procedural concerns.

Justice Brett Kavanaugh dissented, emphasizing the importance of resolving this issue. According to Kavanaugh, dismissing the case likely reflects the court's reluctance to address a complicated mootness argument raised by the plaintiffs, who claimed LabCorp appealed an outdated class-certification order. Kavanaugh argued this mootness claim was insubstantial and urged the court to decide the central issue.

The dispute began when LabCorp introduced touchscreen check-in kiosks in 2017, which plaintiffs claimed were inaccessible to legally blind users, violating the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act. A district court initially certified a class of legally blind California residents who faced barriers due to LabCorp's kiosks. LabCorp argued that this definition included people who had never intended to use the kiosks, thus comprising uninjured individuals.

The Ninth Circuit upheld the certification, relying on precedent permitting class certification even when "more than a de minimis number" of uninjured members were included. LabCorp argued that U.S. appeals courts remain divided on this issue, which affects billions of dollars across class-action litigation nationwide.

Deepak Gupta, the plaintiffs’ lead attorney, welcomed the decision, stating that "class actions are a critical tool for ensuring access to the courts," adding that the dismissal leaves "the law of class actions intact, allowing people to band together to hold powerful corporations accountable for their misconduct."

Justice Kavanaugh argued in his dissent that federal courts should never certify damages classes containing uninjured individuals, asserting that such overly broad classes create unjustified financial risks for businesses and potentially harm consumers and employees by prompting costly settlements.

Ralph Kalfayan, a prominent California class-action attorney not involved in this matter, commented positively on the ruling: "The Supreme Court's decision to leave this issue unresolved actually supports the rights of potential class members. By not explicitly restricting classes to only clearly injured individuals, lower courts retain the flexibility to certify broader classes, thereby increasing access to justice for plaintiffs who might otherwise be excluded. This openness can ultimately strengthen class-action litigation as a tool for accountability."

Ralph Kalfayan further noted that "Justice Kavanaugh’s dissent highlights the ongoing tension between protecting businesses from potential financial risks and ensuring access to justice for plaintiffs. However, the plaintiffs' perspective underscores the importance of maintaining an inclusive approach that empowers individuals to unite against corporate misconduct."

The Supreme Court's decision leaves unresolved significant questions about class-action certifications, likely continuing to generate debate and litigation in lower courts.