132831P.pdf   01/13/2015  Laura Powers  v.  Credit Management Services, In
   U.S. Court of Appeals Case No:  13-2831
   U.S. District Court for the District of Nebraska - Omaha   
   [PUBLISHED] [Loken, Author, with Wollman and Murphy, Circuit Judges] 
   Civil case - Class Actions. In this action alleging defendant's 
   standard-form complaints and discovery requests violated various 
   provisions of the Fair Debt Collections Practices Act and the Nebraska 
   Consumer Protection Act, the court erred in certifying four classes of 
   Nebraska consumers as the court did not conduct the rigorous analysis of 
   what plaintiffs must prove to prevail on their facial invalidity theories; 
   the standard-form complaint classes do not meet the commonality, 
   predominance and superiority requirements of Rule 23; class certification 
   of the standard-form discovery requests was also improper because 
   plaintiffs' facial invalidity claims do not meet the commonality and 
   predominance requirements of Rules 23(a) and 23(b)(3)