In Devlin v. Scardelletti, 536 U.S. 1 (2002), an unnamed class member objected to the class settlement at the fairness hearing, but did not successfully intervene in the proceedings. Id. at 8-9. The Supreme Court held that an unnamed class member's failure to intervene does not implicate standing. Id. at 6. Rather, it concluded that the real issue is whether or not the class member is a "party" for purposes of appeal. Id. at 7. The Supreme Court observed that the right to appeal is not restricted to a case's named parties. Id. at 12 (citing Blossom v. Milwaukee & Chicago R.R., 68 U.S. 655, 17 L. Ed. 673 (1864); Hinckley v. Gilman, Clinton, & Springfield R.R., 94 U.S. 467, 24 L. Ed. 166 (1877); United States Catholic Conference v. Abortion Rights Mobilization, Inc., 487 U.S. 72, 76, 101 L. Ed. 2d 69, 108 S. Ct. 2268 (1988)). The "label 'party' does not indicate an absolute characteristic, but rather a conclusion about the applicability of various procedural rules that may differ based on context." Id. at 10. Thus, the procedural rules governing class actions sometimes require unnamed parties to be treated as parties or nonparties in order to ease the administration of class litigation. The Court listed as an example the treatment of unnamed class members as parties for statute of limitations purposes but as nonparties for diversity purposes. Id. However, the most important consideration was that the unnamed class members would be bound by the class settlement. Id. Thus, noted the Court: it is this feature of class action litigation that requires that class members be allowed to appeal the approval of a settlement when they have objected at the fairness hearing. To hold otherwise would deprive nonnamed class members of the power to preserve their own interests in a settlement that will ultimately bind them, despite their expressed objections before the trial court. Id. The unnamed class member in Devlin was a "party" for purposes of the appeal. Under Texas jurisprudence, an appeal can generally only be brought by a named party to the suit. In short, the petitioner appeared at the fairness hearing and presented his objection. The issue was therefore not whether appearance was required to be a party for purposes of appeal, but whether intervention was also required. Nevertheless, the Supreme Court held that appearing and objecting were required to be considered a party with the right to appeal. Browne claims that the Notice of Class Settlement in this case gave objectors the option to appear or not, and that she still can appeal because she filed a written objection.