When Is An Individual's Claim Typical ?

In Baughman v. State Farm Mut. Auto. Ins. Co. (2000), 88 Ohio St. 3d 480, 727 N.E. 2d 1265, the Ohio Supreme Court discussed the issue of typicality very extensively. The court stated the requirement of typicality serves the purpose of protecting absent class members and promoting the economy of class actions by ensuring that the interests of the named plaintiffs are substantially aligned with those of the class. Baughman, 88 Ohio St. 3d 480. Typicality does not require exact identity of claims. The defenses or claims of the class representatives must be typical of the defenses or claims of the class members. They need not be identical. Planned Parenthood Assn. of Cincinnati, Inc. v. Project Jericho (1990), 52 Ohio St. 3d 56, 556 N.E. 2d 157. In Baughman, the court stated that "a plaintiff's claim is typical if it arises from the same event or practice or course of conduct that gives rise to the claims of other class members, and if his or her claims are based on the same legal theory. Baughman, supra at 485.