Is there an obligation of a named plaintiff to act as a named representative in a class action?

Contrary to appellees reasoning, adequate class counsel cannot make up for inadequate class representatives. "Both class representatives and class counsel have responsibilities to absent members of the class." Maywalt v. Parker & Parsley Petroleum Co ., 67 F.3d 1072, 1078 (2d Cir. 1995) (citation omitted). The decision "as to the course to be followed ... cannot rest entirely with either the named plaintiffs or with class counsel." Id . at 1079. Likewise, it is not incumbent upon class members to intervene to preserve their right to named representatives. Due process "requires that the named plaintiff at all times adequately represent the interests of the absent class members." Phillips Petroleum Co ., 472 U.S. at 812, 105 S.Ct. 2965 (emphasis added). To ensure that named representatives do so, "an absent class-action plaintiff is not required to do anything. He may sit back and allow the litigation to run its course, content in knowing that there are safeguards provided for his protection." Id. at 810, 105 S.Ct. 2965.