The New Jersey Supreme Court has clarified the applicability of aggregate proofs, as opposed to actual damages. Justice Anne Patterson wrote the opinion in Little v. Kia Motors America, a class action involving claims over faulty brakes. The Court rejected the plaintiff’s theory of damages, which was based on the cost of brake repairs on classwide aggregate proofs.
“A class action does not dispense with traditional burdens of proof in the name of efficiency; to the contrary, it leaves the parties’ legal rights and duties intact and the rules of decision unchanged,” Patterson wrote. “Before admitting aggregate proof of damages in a class action, a court must undertake a careful inquiry to ensure that the proposed evidence does not deprive the defendant of a meaningful opportunity to contest the plaintiff’s claims.”
The Court concluded the trial court had “properly ordered individualized proof of damages based on the actual costs incurred by the class members,” and upheld the grant of defendant’s motions for a new trial and for partial decertification of the class, since the trial evidence showed “no single factual pattern on the limited question of damages.”