LaPray v. Compaq

In this landmark class-certification case, Beck Redden represented Compaq Computer Corporation before the Texas Supreme Court in an appeal that established several important precedents regarding Rule 42(b) actions seeking declaratory or injunctive relief. After trying the case and appealing it to the intermediate court of appeals, David Beck argued the case for Compaq in the Supreme Court, successfully convincing the Court to reverse both lower court judgments. The Court held that (1) trial courts must explicitly consider whether absent class members should be given notice and an opportunity to opt-out of the case, at least where damages are also claimed, and (2) the class can be certified only if it is sufficiently cohesive and homogeneous. The Court found that even though the computers sold by Compaq each had an identical warranty, each individual claim would have to be analyzed to determine which state law applied, making the case inappropriate for class treatment.