Court Denies Class Certification in Car Parts Antitrust Suit

In Perez et al. v. State Farm Mutual Automobile Insurance Company et al., Northern District of California Judge James Ware dismissed a putative class action against State Farm Mutual Insurance Company and four other insurers.  In their suit, plaintiffs alleged that the insurers colluded to exclusively offer “junk” policies that shut competitors out of the market and set up a sham organization, the Certified Automotive Parts Association, to prevent competition over auto repair parts.  Defendants challenged plaintiffs’ class certification and sought to strike the testimony of plaintiffs’ expert, Allen Wood, who testified on the issue of evaluation of car parts.  Defendants argued that while Wood attempted to perform a “systematic review” of the relevant material at issue, he didn’t meet generally accepted, basic statistical requirements for a valid analysis of that kind.  The court agreed with the defendants and struck Wood’s testimony, holding that Wood didn’t establish any workable system for picking which surveys and reports to include in his analysis and his process did not rise to the level of methodology, and was not admissible into evidence.  The court further held that because Wood’s testimony was excluded, plaintiffs failed to provide an admissible methodology for categorizing car parts.  Therefore, their move for class certification was denied with prejudice.

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