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Fourth Circuit Reiterates that Absent Class Members Must Suffer Actual Harm

On January 23, 2025, the Fourt Circuit, in Alig v. Rocket Mortg., LLC, No. 22-2289, 2025 WL 271563 (4th. Cir. Jan. 23, 2025), reversed the District Court’s decision that a certified class action. In Alig, the plaintiffs filed a class action lawsuit against Quicken Loans, Inc. (now Rocket Mortgage), and alleged that the appraisals for the refinancing of their homes were not “independent’ because the defendants provided the homeowners’ estimates of their homes’ value to the appraisers. Thus, the plaintiffs alleged that the appraisals that they paid for were “worthless.”

The District Court certified a class of [a]ll West Virginia citizens who refinanced mortgage loans with Quicken, and for whom Quicken obtained appraisals through an appraisal request form that included an estimate of value of the subject property,” which amounted to 2,769 loans. The court then granted summary judgment to the plaintiffs and class members and awarded them more than $10.6 million.

Read the full article by Matthew D. Berkowitz, Esq. on the Legal Ethics Blog.

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