Must Individuals Named in Class Actions Suffer Actual Harm or Damage?

Ganley Chevrolet, Inc., et al. v. Jeffrey Felix et al., Case No. 2013-1746

Eighth District Court of Appeals (Cuyahoga County)

ISSUES:

- May a class action include individuals who did not sustain actual harm or damage from the challenged conduct?

- Does a class action brought under the Ohio Consumer Sales Practices Act require the consumers to have suffered actual damages from the alleged misconduct?