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

Summary

The Alabama Supreme Court vacated the trial court's order certifying a nationwide class of third‑party payors and remanded the case, holding that BCBSAL failed to satisfy the predominance requirement of Rule 23(b)(3). The Court reasoned that unjust‑enrichment claims vary by state and generally require proof of mistake or misconduct, so common questions of law do not predominate. Justice Woodall dissented, arguing that BCBSAL lacked standing and the action should be dismissed.