Abstract:
Abstract: In September 1994, the United States District Court for the Northern
District of Alabama approved a multi-billion dollar settlement in a global class action for
breast implant recipients. The court concluded its opinion by excluding women from
Australia, Ontario and Quebec from the settlement. After examining U.S. class action
procedural. requirements and analyzing the District Court's opinion, this Comment argues
that the court improperly applied the procedural requirements for a class action to the
detriment of the potentially injured women from Australia, Ontario and Quebec.