Sixth Circuit -- Pipefitters Local 636 v. Blue Cross Blue Shield of Mich

Pipefitters Local 636 v. Blue Cross Blue Shield of Mich 

 Class certification reversed - the fact-specific question of whether an entity was acting as an ERISA fiduciary means that the class is not a superior method of adjudication.  Given legitimate variation sin facts, non-class action would not subject deft to incompatible standards of conduct/conflicting affirmative duties.