Seventh Circuit On Expert Opinions

In American Honda Motor Co. v. Allen, the Seventh Circuit Court of Appeals held that when an expert’s opinion is critical to class certification, a district court must conclusively rule on any challenge to the expert’s qualifications or submissions, performing a full Daubert analysis if necessary, before ruling on a class certification motion. American Honda is the latest in a series of Seventh Circuit cases to emphasize the rigorous fact, and often merit-based analysis district courts must undertake before ruling on a class certification motion. It is also consistent with, and expands upon, the developing law in other circuits. See, e.g., In re Hydrogen Peroxide Antitrust Litig., 553 F.3d 305 (2d Cir. 2008) (vacating order granting class certification where district court did not adequately consider expert opinions).