Class Actions, Standing, and the Blind: What LabCorp v. Davis Means for the Future of Federal Litigation
In Laboratory Corp. of America v. Davis, the U.S. Supreme Court finds itself entangled in yet another case that raises fundamental constitutional questions—while simultaneously showcasing the procedural misfires that have become oddly common this term. The central issue? Whether a federal court can certify a class action that includes individuals who have suffered no legal injury.
LabCorp, one of the nation’s leading diagnostic laboratories, introduced automated self-service kiosks in its facilities to streamline check-ins. The technology has proven popular among patients—except, critically, those who are blind or visually impaired. The kiosks, it turns out, are inaccessible to the blind. As a result, plaintiffs filed a class action alleging that the kiosks discriminate against them, violating federal disability law and creating barriers to equal service.
Here’s where it gets legally complex: the proposed class isn’t limited to blind individuals who tried to use the kiosks and were unable to. Instead, the class (at one stage) was so broadly defined that it included all blind individuals exposed to the kiosks, regardless of whether they even knew of the kiosks or attempted to use them. LabCorp argues that this overly inclusive definition sweeps in uninjured plaintiffs—individuals with no standing under Article III of the Constitution.
⚖️ The Injury Requirement and Constitutional Standing
At the heart of LabCorp’s argument lies a foundational principle of federal jurisdiction: courts can only hear cases involving an actual “case or controversy,” which requires a cognizable injury. LabCorp asserts that certifying a class that includes individuals with no concrete injury violates Article III’s standing requirements.
The concern is more than academic. If the class includes uninjured parties, LabCorp fears the specter of a coerced, outsized settlement—a phenomenon that some justices, particularly on the conservative wing, have called the “blackmail settlement” problem. Faced with massive potential liability and reputational damage, companies often settle rather than risk trial, even when the merits are weak.
🔍 Procedural Puzzle: What Did the Lower Courts Actually Decide?
But a procedural glitch may derail the high-stakes debate before it ever reaches the merits.
The class definition at the center of LabCorp’s appeal was not the one certified by the district court. Initially, the court limited the class to blind individuals who either tried or wanted to use the kiosks—a group that, arguably, had standing. LabCorp objected, leading the plaintiffs to broaden the class, presumably to capture a more uniform injury. The appellate court, however, reviewed the case based on LabCorp’s original appeal, before the class definition was expanded.
This mismatch has left the Supreme Court with a murky record. The justices are now tasked with deciding whether the key issue—whether a class may include uninjured parties—is even properly before them. The procedural posture raises the prospect that the Court may dismiss the case as improvidently granted, avoiding a sweeping ruling.
🧭 Slippery Slopes and Unclear Rules
Even if the Court reaches the merits, LabCorp’s position isn’t without complications. Although its brief leans heavily on the “no injury, no standing” argument, the company concedes that including a few uninjured class members might be acceptable in some situations. The problem, it claims, is one of degree: too many uninjured individuals make the class improper.
This raises a thorny legal question: how many uninjured class members are too many? Is there a constitutional threshold, or is this merely a question of Rule 23 certification and commonality?
Some justices may find LabCorp’s argument too imprecise to warrant judicial intervention. They might argue that uninjured class members can simply be excluded at the remedies stage. Others—especially those skeptical of class actions—may see this as an opportunity to further tighten the standing requirements in federal court.
🧠 Broader Implications for Civil Rights and Class Action Law
This case has significant implications beyond the immediate facts. If the Court rules that classes cannot include uninjured members, civil rights litigators may face new hurdles when bringing class claims—especially those involving systemic discrimination where harm can be diffuse or vary in degree. Conversely, a ruling affirming the current standards could empower broader class litigation, particularly in areas like consumer protection and disability rights.
Regardless of the outcome, LabCorp v. Davis reflects a deeper tension in federal courts: how to balance efficiency, fairness, and constitutional limits in collective litigation. Whether the Court delivers a clear rule or punts on procedural grounds, the case offers another reminder of how critical class definitions—and appellate timing—can be.
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