Appeals – Plaintiff lacks standing after he voluntarily settles his individual claims

Where the plaintiff voluntarily settled his individual claims, he lacked standing to appeal the district court’s order decertifying a class and collective action.

Background

James Mebane brought a class-action lawsuit against his former employer, GKN Driveline North America Inc., alleging that violations of the Fair Labor Standards Act, or FLSA, and the North Carolina Wage and Hour Act, or NCWHA, resulted in unpaid overtime compensation and unpaid wages.

The district court certified two classes under Federal Rule of Civil Procedure 23 and conditionally certified an FLSA collective action. After developments in the litigation, however, the court decertified the classes and the collective action.

Mebane now appeals the district court’s decertification order. But before he filed his notice of appeal, Mebane voluntarily settled his individual FLSA and NCWHA claims in the district court. GKN thus argues that Mebane lacks standing to appeal the district court’s decertification order.

Analysis

The Supreme Court has recognized two concrete interests in the class action context. First, a class representative has a concrete interest in the substantive claim he or she asserts. Second, a class representative may assert a distinct procedural right to represent the interests of similarly situated individuals, which can give rise to an interest in shifting the costs of litigation to the remainder of the class.

Following the Supreme Court’s guidance, this court has recognized that a plaintiff who involuntarily loses an interest in his substantive claims nevertheless may be able to rely on the second, representative interest to establish standing to appeal an adverse certification ruling. But when a putative class plaintiff voluntarily dismisses the individual claims underlying a request for class certification, the second, representative interest cannot supply standing to appeal because there is no longer a self-interested party advocating for class treatment in the manner necessary to satisfy Article III standing requirements.

Applying these principles, Mebane lacks standing to appeal the district court’s decertification order. In the settlement agreement, Mebane generally waived all remaining claims in this suit. As Mebane concedes, that general waiver covered his substantive FLSA and NCWHA claims. Mebane therefore has no remaining interest in his substantive claims to establish standing to pursue this appeal.

Nor can Mebane rely on any interest in shifting the costs of litigation to the remainder of the class or his contractual reservation of the right to appeal the decertification order. This court categorically held that when a putative class plaintiff has voluntarily settled or dismissed his individual substantive claims, he no longer possesses a sufficiently concrete interest in the certification question to satisfy the case-or-controversy requirement of Article III.

Mebane protests that his settlement agreement with GKN explicitly preserved the right to appeal the decertification order, seek attorney’s fees and costs and request a service award in connection with related cases. This court disagrees. It has previously rejected the idea that the language of a plaintiff’s settlement agreement is determinative of that plaintiff’s stake in an appeal. A plaintiff who voluntarily dismisses the individual claims underlying a request for class certification has no standing to appeal a district court’s class certification ruling.

Dismissed.

Mebane v. GKN Driveline North America, Inc., Case No. 25-2191, June 2, 2026. 4th Cir. (Rushing), from MDNC at Greensboro (Biggs). Gilda Adriana Hernandez for Appellant. Paul DeCamp for Appellee. VLW 026-2-196. 11 pp.

Full-Text Opinion
VLW 026-2-196