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Zahn v. International Paper Co.

ELR Citation: ELR 20616
Nos. No. 71-2157, 469 F.2d 1033/4 ERC 1619/(2d Cir., 09/07/1972)

A diversity case may not proceed as a class action when the named plaintiffs meet the jurisdictional amount but the unnamed representatives of the class do not. This defect may not be cured by the named plaintiffs allocating part of their share of punitive damages to the class members....

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