Robinson v. Texas Automobile Dealers Ass'n

United States Court of Appeals Fifth Circuit F I L E D In the October 5, 2004 United States Court of Appeals Charles R. Fulbruge III for the Fifth Circuit Clerk _______________ m 03-40691 _______________ BERT A. ROBINSON, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED; MARY LUMAN, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED; TOYIA URBANIAK, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED; KIRK T. GARNER, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, Plaintiffs-Appellees, VERSUS TEXAS AUTOMOBILE DEALERS ASSOCIATION; ET AL., Defendants, TEXAS AUTOMOBILE DEALERS ASSOCIATION; ALLISON CHEVROLET, DOING BUSINESS AS ALLISON CHEVROLET OLDSMOBILE; BASS CHEVROLET, DOING BUSINESS AS PETERS CHEVROLET; MILE PILE AUTOPLEX, DOING BUSINESS AS MIKE PILE JEEP-EAGLE; ALFORD CHEVROLET-GEO; ET AL.; PLAINS CHEVROLET, INC., DOING BUSINESS AS HIGH PLAINS AUTO CENTER; WESTGATE CHEVROLET, DOING BUSINESS AS WESTGATE KIA, DOING BUSINESS AS RAY JONES CHEVROLET; W.O. BANKSTON LINCOLN-MERCURY, INC., DOING BUSINESS AS W.O. BANKSTON LINCOLN-MERCURY SAAB, INC.; W.O. BANKSTON NISSAN; BANKSTON NISSAN IN IRVING, INC.; ET AL.; GENE MESSER CADILLAC; GENE MESSER IMPORTS; GENE MESSER FORD, INC., DOING BUSINESS AS GENE MESSER KIA, DOING BUSINESS AS CREDIT CONNECTION, DOING BUSINESS AS FORD ESP. SW REG. PROC. CTR., DOING BUSINESS AS GENE MESSER VOLKSWAGEN; GENE MESSER FORD OF AMARILLO, INC., DOING BUSINESS AS GENE MESSER CADILLAC, DOING BUSINESS AS GENE MESSER JEEP/EAGLE; FOYT MOTORS, INC., DOING BUSINESS AS A.J. FOYT HONDA; SMC LUXURY CARS, INC., DOING BUSINESS AS STERLING MCCALL LEXUS; SOUTHWEST TOYOTA, INC.; RODEO CHRYSLER-PLYMOUTH, INC., DOING BUSINESS AS RODEO DODGE, DOING BUSINESS AS VILLAGE CHRYSLER-PLYMOUTH; MIKE SMITH AUTOPLAZA, DOING BUSINESS AS MIKE SMITH HONDA, DOING BUSINESS AS MIKE SMITH MITSUBISHI, DOING BUSINESS AS MIKE SMITH JEEP/EAGLE; TOWN NORTH IMPORTS, DOING BUSINESS AS TOWN NORTH MITSUBISHI; TOWN NORTH NISSAN; TOWN NORTH SUZUKI, Defendants-Appellants. _________________________ Appeal from the United States District Court for the Eastern District of Texas _________________________ Before SMITH, GARZA, and PICKERING, (“TADA”) and some of its members appeal,1 Circuit Judges. pursuant to FED. R. CIV. P. 23(f), the condi- tional certification of a plaintiff class of mil- JERRY E. SMITH, Circuit Judge: The Texas Automobile Dealers Association 1 Defendants submitted three briefsSSone from TADA and two from individual dealers. Because they contain similar arguments, we refer to them collectively. 2 lions of consumers who have purchased a car Alleging violations of section 4 of the in Texas since 1994. Because the proposed Clayton Act4 and section 1 of the Sherman class does not meet the requirements of FED. Act,5 plaintiffs sued the TADA and most deal- R. CIV. P. 23(b)(3), we reverse the certifica- erships6 that adopted the TADA plan. Spe- tion and remand. cifically, plaintiffs allege that, by uniformly imposing the VIT as a line item, defendants are I. engaged in horizontal price-fixing, conspired Effective January 1, 1994, Texas altered the to create a horizontal price-fixing regime, and manner in which it calculated and assessed the have been unjustly enriched. Vehicle Inventory Tax (“VIT”) imposed on automobile dealers. Before the alteration, the Plaintiffs moved to certify plaintiff and de- tax was just another overhead expense to be fendant classes based on FED. R. CIV. P. 23- absorbed as part of the sales price. As a result (b)(2)7 and (3),8 proposing a class consisting of of the amendments, the state began calculating the VIT as a percentage of the sales price of each car sold. 3 (...continued) as the VIT. Based on the recommendations of the Com- missioner of the Office of Consumer Credit 4 15 U.S.C. § 15 (stating that “any person who and of the Texas Comptroller of Public shall be injured in his business or property by rea- Accounts, and on a statement from a sponsor son of anything forbidden in the antitrust laws may of the legislation, the TADA advised2 its sue therefor[,] without respect to the amount in members to itemize the VIT as a separate item controversy, and shall recover threefold the dam- on each sales contract and to charge it in ad- ages by him sustained, and the cost of suit, in- dition to the regular “sales” or “cash” price. cluding a reasonable attorney’s fee”). Although dealerships could pursue the previ- 5 15 U.S.C. § 1 (“Every contract, combination ous approach of including the VIT as an un- in the form of trust or otherwise, or conspiracy, in disclosed part of the listed sales price, a large restraint of trade or commerce among the several number of dealerships followed the TADA States, or with foreign nations, is hereby declared protocol and listed the VIT3 separately. to be illegal.”). 6 Plaintiffs sued those dealerships that belonged 2 The TADA did not require its members to to the TADA and charged a VIT. Plaintiffs allege follow this plan. It did, however, distribute stan- the presence of “approximately 600 defendant dardized forms and did conduct numerous “educa- Dealers.” The district court provided a larger tional sessions” to promote this particular ap- figure, stating that “the court does have some proach. Not surprisingly, the two sides view the concerns over the manageability of a suit against educational program and its recommendations over a thousand defendants.” through different lenses. 7 Rule 23(b)(2) allows for injunctive relief 3 Some dealerships used different terms for the where “the party opposing the class has acted or separate charge, including, inter alia, “ad valorem refused to act on grounds generally applicable to tax,” “personal property tax fee,” and “VIT.” For the class[.]” The district court denied the rule the sake of convenience, we refer to this extra fee 23(b)(2) motion in one paragraph, and plaintiffs do (continued...) (continued...) 3 all persons and entities who purchased a individual issues10 and opining that, despite the new or used motor vehicle in Texas during court’s “concerns over the manageability of a the period of January 1, 1994 through the suit against over a thousand defendants[,] this date of class certification herein, from a class action is the superior method for ad- motor vehicle dealership which was a mem- judicating this controversy.” ber of the [TADA] at the date of sale, and who were charged a ‘vehicle inventory tax,’ II. ‘inventory tax,’ ‘Texas vehicle inventory The district court erroneously certified the tax,’ ‘ad valorem tax,’ ‘ personal property plaintiff class. Facts necessary to sustain a tax fee,’ ‘P/P tax fee,’ ‘VIT,’ or similarly possible horizontal price-fixing injury do not identified ‘ fee or charge’ as an addition to predominate. Additionally, the district court the sales price or cash price of the vehicle . did not conduct sufficient inquiry into the man- ... agement of this complex, multiparty action. As the district court noted, “Potentially, mil- “We review the certification of a class for lions of consumers are included in the pro- abuse of discretion.” O’Sullivan v. Country- posed class.” wide Home Loans, Inc., 319 F.3d 732, 737 (5th Cir. 2003). To make a determination on Although declining to certify a defendant class certification, a district court must con- class,9 the court conditionally certified the duct an intense factual investigation. “There proposed plaintiff class, finding that common are no ‘hard and fast rules . . . regarding the issuesSSincluding the common presence of the suitability of a particular type of antitrust case VIT in all sales contractsSSpredominate over for class action treatment.’ Rather, ‘the unique facts of each case will generally be the determining factor governing certification.’” 7 Bell Atl. Corp. v. AT&T Corp., 339 F.3d 294, (...continued) not challenge that order. 301 (5th Cir. 2003) (quoting Alabama v. Blue Bird Body Co., 573 F.2d 309, 316 (5th Cir. 8 If the four requirements of rule 23(a) are met, 1978)). a court may certify a class pursuant to rule 23- (b)(3) if it “finds that the questions of law or fact Although we review the certification deci- common to the members of the class predominate sion using a deferential standard, “[a] district over any questions affecting only individual mem- court must conduct a rigorous analysis of the bers, and that a class action is superior to other rule 23 prerequisites before certifying a class.” available methods for the fair and efficient adjudi- Castano v. Am. Tobacco Co., 84 F.3d 734, cation of the controversy.” Rule 23(b)(3) also in- 740 (5th Cir. 1996). Additionally, the district cludes a non-exclusive list of four “matters per- court’s “‘decision must be exercised within the tinent to the findings” of superiority and numer- framework of Rule 23.’” McManus v. Fleet- osity. 9 With respect to the defendant class, the court 10 concluded that “each Defendant has the absolute As part of its analysis, the district court ap- right to individually defend itself by presenting di- plied the parol evidence rule to exclude possible rect evidence of noninvolvement in any alleged evidence regarding negotiations over those sales conspiracy.” contracts. 4 wood Enters., 320 F.3d 545, 548 (5th Cir. conditionally, “it does not follow that the 2003) (quoting Castano, 84 F.3d at 740). We rule’s requirements are lessened when the class review a district court’s conclusions of law de is conditional.”14 Castano, 84 F.3d at 741. novo.11 III. “The party seeking certification bears the A. burden of demonstrating that the requirements In evaluating the predominance require- of rule 23 have been met.”12 Such require- ment, we take care to inquire into the sub- ments include both the four factors of rule stance and structure of the underlying claims 23(a)SSnumerosity, commonality, typicality, without passing judgment on their merits. “Al- and adequacySSand the two requirements of though ‘the strength of a plaintiff's claim rule 23(b)(3). Because defendants do not con- should not affect the certification decision,’ the test the plaintiffs’ satisfaction of the rule 23(a) district court must look beyond the pleadings requirements, we address only whether they to ‘understand the claims, defenses, relevant satisfied rule 23(b)(3). facts, and applicable substantive law in order to make a meaningful determination of the “Rule 23(b)(3) demands of a party seeking certification issues.’”15 class certification . . . the burden of demon- strating (1) that questions common to the class Despite the fact that such an inquiry “does members predominate over questions affecting not resolve the case on its merits,” it helps only individual members and (2) that class “prevent[] the class from degenerating into a resolution is superior to alternative methods of series of individual trials.” O’Sullivan, 319 adjudication of the controversy.” Bell Atl., F.3d at 738. Making a meaningful determina- 339 F.3d at 297. Although such language may tion of the certification issues “entails iden- resemble the words of rule 23(a), “[t]he pre- tifying the substantive issues that will control dominance and superiority requirements are the outcome, assessing which issues will pre- ‘far more demanding’ than is [R]ule 23(a)(2)’s dominate, and then determining whether the commonality requirement.”13 Despite the fact issues are common to the class.” Id. that the district court granted certification only Plaintiffs assert three separate claims,16 but 11 O’Sullivan, 319 F.3d at 737 (“Because, how- 14 ever, a court abuses its discretion when it makes an Castano, 84 F.3d at 741. error of law, we apply a de novo standard of 15 review to such errors.”). McManus, 320 F.3d at 548 (quoting Cas- tano, 84 F.3d at 744). 12 Id. at 737-38 (citing Allison v. Citgo Pe- 16 troleum Corp., 151 F.3d 402, 408 (5th Cir. The plaintiffs originally alleged three different 1998)). See also Castano, 84 F.3d at 740 (“The counts, two of whichSSthe horizontal price fixing par ty seeking certification bears the burden of and conspiracy to fix pricesSSfocus on the Clayton proof.”). Act. The third charges unjust enrichment. Although plaintiffs apparently did not request 13 O’Sullivan, 319 F.3d at 738 (quoting Am- certification on the unjust enrichment count, the chem Prods. v. Windsor, 521 U.S. 591, 624 district court recognized all three actions and (1997)). (continued...) 5 we need consider only whether they have de- also called ‘impact,’ means that the antitrust fined a class whose members suffered an an- violation must cause injury to the antitrust titrust injury. One common factor links all as- plaintiff.” Id. “[I]n a price fixing case, impact pects of the suitSSnamely, payment of the may be shown simply by proof of purchase at VIT. If the proposed class contains too broad a price higher than the competitive rate.” Id. a sample of consumers for something action- (citing Blue Bird, 573 F.2d at 317). Although able under the Clayton Act to predominate, the it “is generally true [that] ‘antitrust price-fixing conspiracy claim will fail as well.17 If the mere cases are particularly suitable for class action payment of a VIT does not adequately tie the treatment,’” the proposed class still has to interests of the class members together for meet the three aforementioned requirements. purposes of any Clayton Act violations, the Blue Bird, 573 F.2d at 322.19 class will similarly fail for any purported claim of unjust enrichment. Class members do not necessarily have to demonstrate impact through individualized evi- B. dence. Instead, “by demonstrating, through “Private antitrust liability under § 4 of the generalized proof, that the competitive [price] Clayton Act requires the showing of (1) a vi- for groups of or for individual class members olation of the antitrust laws, (2) the fact of existed at least over a range, the highest point damage, and (3) some indication of the of which was less than the [price] actually amount of damage.” Nichols v. Mobile Bd. of paid[,]” a party may rely on more general Realtors, Inc., 675 F.2d 671, 676 (Former 5th proof.20 Consequently, the baseline or “com- Cir. 1982). Because this appeal concerns only petitive” price determines whether a party may class certification questions, we address only use generalized proof to sustain a claim of hor- whether the facts and law necessary to sustain izontal price fixing.21 a horizontal price-fixing action predominate in the proposed class.18 “The requirement of the ‘fact of damage,’ 19 The Blue Bird panel, 573 F.2d at 322, de- scribed some of the requirements of a “classic” price-fixing conspiracy: “[A]ll legal and factual 16 (...continued) issues relating to the conspiracy” should bear a un- generally certified the plaintiff class. iform relationship “to all those allegedly harmed,” and “the products involved [and] the purchasers 17 “Under the rule of reason, the plaintiff must [should] be standardized.” establish two elements basic to an anticompetitive 20 conspiracy: (1) that the defendant engaged in some Nichols, 675 F.2d at 678 (citing Bogosian v. form of joint action and (2) that this joint action Gulf Oil Corp., 561 F.2d 434, 455 (3d Cir. 1977)). amounted to an unreasonable restraint of trade.” 21 Consol. Metal Prods., Inc. v. Am. Petroleum Inst., Bogosian (which is not binding on us but 846 F.2d 284, 293 (5th Cir. 1988) (emphasis which is informative) allows for generalized proof, added). provided plaintiffs show “a nationwide con- spiracy[,] the result of which was to increase prices 18 Given the limited nature of the appeal, we to a class of plaintiffs beyond the prices which assume arguendo that the uniform addition and would obtain in a competitive regime[.]” itemization of the VIT violate the Clayton Act. Bogosian, 561 F.2d at 455 (emphasis added). 6 The predominance of facts unrelated to the final purchase price for every consumer in the price-fixing claim should not provide support class. Under plaintiffs’ theory, if the charge for certifying a class. Otherwise, commonali- did not exist, the consumer would pay that ties based on irrelevant matters such as geo- much less, or at least some amount less.22 The graphic location, sex of a party, or date of pur- court adopted these assumptions in its chase might allow for class certification. We analysis. must determine whether the mere payment of a VITSSunaccompanied by any other evi- Such an assumption defies the realities of denceSSprovides enough information such that the haggling that ensues in the American mar- a party may sustain a price-fixing suit on behalf ket when one buys a vehicle. Although some of the entire class. purchasers certainly negotiate a price that ex- cludes taxes, titles, and fees, others negotiate C. with an eye to the “bottom line.”23 Bottom- By including in the plaintiff class every line purchasers base their negotiations on the purchaser who paid a VIT, plaintiffs grouped final purchase price, including every tax, fee, consumers with divergent negotiating histories and surcharge. and removed the predominant factors needed to support this particular horizontal price- If a bottom-line purchaser negotiates for a fixing claim. By incorrectly applying the parol certain priceSSsay, $400 a monthSShe does evidence rule, the district court ignored evi- not pay more because of the presence of the dence that might have helped narrow the class VIT. Even if the dealer does not reduce or or even strengthen its own decision to certify. eliminate the VIT,24 it reduces the pre-VIT Consequently, the proposed class fails the pre- cash price to drop the final price to the agreed- dominance requirement of rule 23(b)(3). upon amountSSin this example, $400 a month.25 The plaintiff class possesses essentially four traits. The buyer must have (1) purchased the vehicle in Texas (2) from a member of the 22 For example, consider a consumer who TADA (3) on or after January 1, 1994, and (4) agreed on a final price of $9,500 and who, as part must have paid a VIT or “similarly identified of that price, paid a VIT of $30. Under plaintiffs’ ‘fee or charge’ as an addition to the sales price theory, if the dealership had not itemized the VIT, or cash price of the vehicle[.]” The key the consumer would have paid only $9,470. component of the underlying suit rests with the fourth element. Plaintiffs repeatedly focus on 23 The recordSSspecifically, the testimony and the sales contract to make the point that “[t]he depositions of auto dealersSSsupports defendants’ injury is the [VIT] charge itself . . . . It is contention that some individuals negotiate in a undisputed that the VIT charge is a component bottom-line fashion. of the ‘bottom line,’ and influences and 24 Defendants introduced evidence that some impacts what the consumer actually pays at the dealers did negotiate over the VIT. In any event, end of every class transaction.” the burden is on plaintiffs to establish the propriety of the class. O’Sullivan, 319 F.3d at 737-38. Plaintiffs assume that the VIT represents an additional charge that artificially increases the 25 Defendants provide a helpful real-life ex- (continued...) 7 To determine whether a purchaser contractsSS“namely that [the dealerships] did negotiated in a top-line or bottom-line fashion, in fact charge, and each Plaintiff did in fact a court would have to hear evidence regarding pay, the VIT.” each purported class member and his transaction. Such an individual examination The district court’s application of the parol would destroy any alleged predominance evidence rule is flawed in at least two respects. present in the proposed class. The offered First, the rule does not apply to an antitrust evidence plainly shows that the class case in which no one disputes the validity and members’ individual negotiation styles prevent terms of the contract. “Both the parol the plaintiffs from arguing that all members of evidence rule and the doctrine of integration the class suffered an antitrust injury just by exist so that parties may rely on the paying a VIT. enforcement of agreements that have been re- duced to writing.” Jack H. Brown & Co. v. D. Toys “R” Us, Inc., 906 F.2d 169, 176 (5th The district court resolved the need for in- Cir. 1990). In the typical case involving the dividual inquiries by applying the parol parol evidence rule, one party might try to evidence rule inappropriately. Under that rule, introduce evidence to challenge the validity of terms in “a writing intended by the parties as a a contract or the contract’s terms.26 final expression of their agreement . . . may be not contradicted by evidence of any prior Here, however, neither side disputes the agreement or of a contemporaneous oral terms of the contracts, and neither argues agreement but may be explained or against the validity of the contracts. If a con- supplemented . . . .” TEX. BUS. & COM. CODE tract lists a VIT at $42, defendants concede ANN. § 2.202 (Vernon 1994). that the buyer owes a $42 VIT payment as part of the final purchase price. Rather, The district court considered any evidence defendants challenge the assumption that the regarding the parties’ negotiations to be viola- parties negotiated every contract in the same tive of the parol evidence rule and excluded it. top-down manner. Such a determination has By so reasoning, the district court focused ex- a direct impact on whether the VIT increased clusively on the express terms of the the total amount paid and on whether the class members may have suffered an alleged price fixing injury. 25 (...continued) ample of a bottom-line negotiation. After running Secondly, even if the parol evidence rule through a number of calculations, a purchaser end- were to apply, the evidence defendants wish to ed up with a round number: $10,150.00. To get to that number, he had to begin with a rather irregular “cash” price of $9408.65. Defendants argue that 26 “what plaintiffs want this Court to accept as an The few antitrust cases that have even men- irrefutable fact is that [the aforementioned tioned the parol evidence rule have done so in the purchaser] negotiated with his dealer until they context of interpreting a settlement agreement aris- agreed upon a price to the penny: $9408.65. That ing out of an antitrust suit. See, e.g., Ingram particular negotiation then, after adding tax and Corp. v. J. Ray McDermott & Co., 698 F.2d 1295, fees, just so happened to add up to the very round 1321 (5th Cir. 1983) (applying the Louisiana parol number of $10,150.00.” evidence rule). 8 offer does not contradict the terms of the re- method for adjudicating this controversy” and spective contracts; as we have said, defendants by not conducting any kind of analysis or assume the validity of the contracts’ terms. discussion regarding how it would administer The proffered evidence, instead, addresses the the trial. Although rule 23(b)(3) lists four negotiations leading up to the terms’ inclusion. factors28 to consider as part of the superiority The evidence will “explain . . . or inquiry, and though more than one factor supplement[]” the terms, TEX. BUS. & COM. might have some relevance, the fourth CODE ANN. § 2.202, so that a fact-finder might considerationSS“the difficulties likely to be en- understand whether the VIT caused an countered in the management of a class ac- antitrust injury.27 tion”SSaddresses the most troublesome aspect of this certification. By applying the parol evidence rule, the dis- trict court made an incorrect assumption re- In considering the superiority requirement, garding the primary issue of the predominance a district court must possess “an understanding inquiry. Instead of worrying about the of the relevant claims, defenses, facts, and presence of the VIT or the purported validity substantive law presented in the case.” Alli- of the contracts, the court should have son, 151 F.3d at 419. A court must consider considered whether the VIT payments always “how a trial on the alleged causes of action would represent an antitrust injury. would be tried.” Castano, 84 F.3d at 752. E. The district court failed to indicate how it Thus, the district court abused its discretion would manage the gigantic plaintiff class and by holding that plaintiffs offered a class in the large number of defendants. Despite ad- which common issues predominate. The court mitting that it had “some concerns over the erred by finding that the mere payment of a manageability of a suit against over a thousand VIT created an antitrust injury and in applying defendants,” the court decided that the the parol evidence rule to exclude evidence re- conditional nature of the certification entitles garding the negotiating styles of the individual it to revoke certification if problems arise with purchasers. the class as defined. Of course, even with re- IV. 28 The district court abused its discretion by The four factors are as follows: finding that “this class action is the superior (A) the interest of members of the class in in- dividually controlling the prosecution or defense of separate actions; (B) the extent and nature of 27 Furthermore, even if the district court cor- any litigation concerning the controversy rectly excluded the detailed evidence regarding the already commenced by or against members of negotiation, plaintiffs could not possibly meet their the class; (C) the desirability or undesirability burden of showing antitrust injury, because, by ex- of concentrating the litigation of the claims in cluding all evidence beyond the language of the the particular forum; (D) the difficulties likely contract, the district court prevented the parties to be encountered in the management of a class from offering evidence of the baseline price. action. Without some sort of baseline or competitive price, plaintiffs cannot show antitrust injury. FED. R. CIV. P. 23(b)(3). 9 spect to a conditional certification, the court have adopted a figure-it-out-as-we-go-along must meet the requirements of rule 23(b)(3). approach that Castano criticized and that other “[I]t does not follow that the rule’s Fifth Circuit cases have not endorsed.29 Thus, requirements are lessened when the class is by failing to consider problems concerning the conditional.” Castano, 84 F.3d at 741. plaintiff class and the significantly large defen- dant group, the district court erred in its su- Assuming arguendo that the plaintiff class periority inquiry. contains sufficient members with cohesive in- terests such that the mere payment of a VIT V. may constitute horizontal price fixing, the dis- In summary, the district court erred in its trict court failed to consider the complications consideration of both elements of rule 23- of the plaintiffs’ and defendants’ presentations (b)(3). In conducting the predominance at trial. For example, on the plaintiffs’ side, inquiry, the court misinterpreted the the court must find jurors who do not belong requirements for an antitrust injury, ignored to the significantly large plaintiff class and the realities of purchasing a vehicle, and must empanel a jury for a lengthy trial. improperly applied the parol evidence rule to exclude evidence regarding the manner in By not certifying a large defendant class, which the class members negotiated their sales the district court also created an unaddressed contracts. The court also abused its discretion problem in balancing two competing interests. by failing to account, in any way, for the First, as the court acknowledges, “each obvious complexities that may arise. Defendant has the absolute right to individually defend itself by presenting direct The certification of the plaintiff class is evidence of noninvolvement in any alleged REVERSED. We REMAND for further pro- conspiracy[.]” In opposing the conspiracy ceedings not inconsistent with this opinion. charge, each of the several hundred defendants likely will want to offer a witness or two to refute any evidence offered in support of the plaintiffs’ position. Simultaneously, however, the parties have an interest in ensuring that the jurors will have 29 a reasonable chance of remembering which For example, Allison distinguished between party presented which evidence. The sheer Rule 23(b)(2) class actions and rule 23(b)(3) class number of individual defendants and the in- actions by explaining that “proposed (b)(2) classes centive to offer individual defenses create the need not withstand a court’s independent probe into the superiority of the class action over other possibility of jurors’ having to base their de- available methods of adjudication[,] as (b)(3) class- terminations on evidence offered throughout a es must.” Allison, 151 F.3d at 414. In Mullen v. long proceeding. Treasure Chest Casino, LLC, 186 F.3d 620, 627 (5th Cir. 1999), the panel affirmed the certification In its certification order, the court did not of a class after describing the trial plan the district indicate that it has seriously considered the ad- court had endorsed, finding that the court did not ministration of the trial. Instead, it appears to abuse its discretion by adopting a “bifurcated-trial plan.” 10