Theodore Frank v. Target Corporation

Wood, Chief Judge.

Inequitable settlements are an unfortunate recurring bug in our system of class litigation. Federal Rule of Civil Procedure 23(e) is designed to minimize such problems, but appeals by class members who object to a settlement indicate that the system still needs improvement. All too often, class counsel negotiate a settlement with substantial attorneys' fees but meager benefits for the class. See, e.g. , Redman v. RadioShack Corp. , 768 F.3d 622 , 638-39 (7th Cir. 2014). Named plaintiffs fail to live up to their ethical obligations as fiduciaries to the class. See, e.g. ,…