Second Circuit Review: Court Clarifies Certification Analysis for Out-of-State Class Members

Litigation partners Martin Flumenbaum and Brad Karp’s latest Second Circuit Review column, “Court Clarifies Certification Analysis for Out-of-State Class Members,” appeared in the August 22 issue of the New York Law Journal. The authors discuss Langan v. Johnson & Johnson and explain that the Second Circuit has now made clear that, for purposes of class action certification of cases on behalf of out-of-state non-party class members, named plaintiffs only need to establish standing for their own claims. Litigation associate Victor Pinedo assisted in the preparation of this article.