Highlights from this issue include: 

• Intervention. The U.S. Court of Appeals for the Ninth Circuit held that after the district court denied a motion to certify a Rule 23(b)(3) damages class, and the class reached a settlement in principle on a Rule 23(b)(2) injunctive relief class-wide basis, a group of absent class members could not intervene to appeal the Rule 23(b)(3) decision.
• Article III Standing and Rule 23(b)(2). The U.S. Court of Appeals for the D.C. Circuit held that courts may award class-wide injunctive or declaratory relief under Rule 23(b)(2) so long as one member of the class has standing.