What is the test for establishing a subclass in a class action?

California, United States of America


The following excerpt is from Petersen v. Bank of Am., 181 Cal.Rptr.3d 330, 232 Cal.App.4th 238 (Cal. App. 2014):

The majority asserts, the ability to organize class actions into appropriate subclasses is important for our purpose here. (Maj. opn., ante, at p. 343.) Subclasses are an important tool for making class actions more efficient (Vasquez v. Superior Court (1971) 4 Cal.3d 800, 821, 94 Cal.Rptr. 796, 484 P.2d 964 ) but, as I emphasized at the outset, this is not a class action.

[232 Cal.App.4th 276]

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