Standing Classily

In Wilson v. Centene Mgmnt. LLC, the Fifth Circuit vacated an order denying class certification, concluding that plaintiffs had established Article III standing at the class-certification stage.

Specifically, the Court held that the named plaintiffs adequately established individual standing through allegations and evidence of injury-in-fact, causation, and redressability: they alleged overcharges for a health insurance policy with materially inaccurate provider directories, the overcharges were fairly traceable to the discrepancy between the promised and actual network, and they would be refunded if successful.

The Court further held that plaintiffs need not prove the precise dollar amount of damages at this stage, stating, “Although the Plaintiffs will ultimately have to prove whether and to what extent they were overcharged based on the inadequacy of the network, they do not need to prove how to measure that injury in dollars at the class-certification stage.”

This opinion differs from the Court’s now-withdrawn, July 2025 opinion, which had formally  adopted the “class-certification approach” to determining standing and held that once individual standing is established, the remaining analysis should occur under Rule 23. This revised opinion expressly declined to resolve a circuit split on this point, analyzing the plaintiffs’ claims under both recognized approaches, and concluding that no choice was necessary because plaintiffs had satisfied both. No. 24-50044, Feb. 19, 2026