Wyeth, Inc., and Wyeth Pharmaceuticals, Inc. v. Blue Cross and Blue Shield of Alabama

Summary

The court held that BCBSAL's standing allegations were distinct from the merits of its unjust-enrichment theory, but vacated nationwide class certification because BCBSAL failed to show that common legal and factual questions predominated under Rule 23(b)(3). The court concluded that significant variations among state unjust-enrichment laws, and uncertainty whether the asserted theory was cognizable in most states, defeated predominance, making it unnecessary to address superiority or the other certification requirements. Justice Woodall, dissenting, would have held that BCBSAL lacked standing because it alleged no injury to a legally protected right and would have directed dismissal.