Baldwin Mutual Insurance Company v. Gloria Mitchell McCain

Summary

The court reversed the order certifying McCain's action as a class action because her individual claims were barred by res judicata based on a prior final judgment involving the same parties and claims. The court held that the prior court had subject-matter jurisdiction and that any first-filed-action objection concerned abatement, not jurisdiction, and had been waived. Because res judicata supplied a unique defense against the sole proposed class representative, she could not satisfy the typicality and adequacy requirements for class certification.