Ex parte Equity National Life Insurance Co

In Ex parte Equity National Life Insurance Co., 715 So. 2d 192 (Ala. 1997), the Court, noting that it considers "federal authorities ... persuasive when it is interpreting Rule 23, Ala. R. Civ. P.", id. at 195, n.2, held: "The United States Supreme Court, applying Rule 23 of the Federal Rules of Civil Procedure, has said that, before issuing any class certification order, a trial court must be 'satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied.' General Telephone Co. of the Southwest v. Falcon, 457 U.S. 147, 155, 102 S. Ct. 2364, 2369, 72 L. Ed. 2d 740 (1982). The essence of this holding, it appears to us, is that every class certification order must, at a minimum, identify each of the four elements of Rule 23(a) and explain in detail how the proponents of the class have met their burden of proving those elements." (715 So. 2d at 194-95.)