State Farm Mut. Auto. Ins. Co. v. Reyher

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The class certification issue presented in this case arose from a dispute concerning the payment of medical bills under the Colorado Automobile Accident Reparations Act (No-Fault Act). Plaintiffs Pauline Reyher and Dr. Wallace Brucker filed suit against State Farm Mutual Automobile Insurance Company (State Farm) alleging that it failed to pay full, reasonable amounts in medical expenses in violation of the No-Fault Act and its own contracts. Plaintiffs subsequently moved to certify two classes that included all insureds and providers, respectively, who submitted medical bills to State Farm and were reimbursed for less than the full amounts. The trial court denied the motion for certification on grounds that Plaintiffs failed (among other things) to establish the "predominance" requirement. The appellate court reversed and remanded the case to enter an order certifying the class. State Farm appealed, arguing that the appellate court's finding of "predominance" was made in error. Upon review, the Supreme Court affirmed the trial court's decision and reversed the appellate court.