Highlights from this issue include: 

• ERISA and Rule 23(b)(1). The U.S. Court of Appeals for the Fourth Circuit held that ERISA claims brought in the context of a defined contribution plan were individualized monetary claims, and thus certification under Rule 23(b)(1) was not appropriate because that subdivision does not require notice or the ability of class members to opt out.
• Pro se Prisoners. The U.S. Court of Appeals for the Sixth Circuit reiterated that a pro se prisoner plaintiff cannot bring a class action on behalf of other prisoners because only experienced counsel with significant resources could provide the level of support necessary to prosecute such a massive suit.
• Incentive Awards. The U.S. Court of Appeals for the Federal Circuit held that district courts are permitted to approve incentive awards in class action settlements. The only circuit that disallows incentive awards is the U.S. Court of Appeals for the Eleventh Circuit.