Kenneth Bell v. Durant Brockett

QUATTLEBAUM, Circuit Judge:

This case involves one of the rarest types of complex litigation, the defendant class action. Defendant class actions are so rare they have been compared to "unicorns." CIGNA HealthCare of St. Louis, Inc. v. Kaiser , 294 F.3d 849 , 853 (7th Cir. 2002). 1 In this case, members of the defendant class argue that the district court erred in certifying the class without simultaneously appointing counsel for the class and in failing to properly analyze the adequacy of class counsel. We agree that the district court failed to follow Federal Rule of Civil Procedure 23 on…