The following excerpt is from Van Gemert v. Boeing Co., 590 F.2d 433 (2nd Cir. 1978):
15 The argument that there is no attorney-client relationship between the absentees and class counsel is not persuasive. A certification under Rule 23(c) makes the Class the attorney's client for all practical purposes, Developments in the Law: Class Actions, 89 Harv.L.Rev. 1318, 1592-97 (1976). The judgment in a class action is not secure from collateral attack unless the absentees were adequately and vigorously represented. Without question, it is settled that the attorney is not free to advocate the interests of the named plaintiffs alone. See Gonzales v. Cassidy, 474 F.2d 67, 75-76 (5th Cir. 1973). And absentees do not cease to be clients simply because they fail to claim their portion of the class recovery.
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