The U.S. Court of Appeals for the Seventh Circuit rejected a class member’s challenge to the $10.2-million settlement agreement reached in a consolidated class action alleging that Unilever U.S., Inc. misrepresented its Suave Professionals® Keratin Infusion 30-Day Smoothing Kit. Reid v. Unilever U.S., Inc., No. 14-3009 (7th Cir., order entered March 25, 2016). Following a stay of the underlying class actions and extensive mediation efforts, the parties reached a settlement in February 2014; two class members objected, then one objector was dismissed from the case.

Applying an abuse-of-discretion standard to review the district court’s approval, the Seventh Circuit considered “(1) the strength of the class’s case, (2) the complexity and expense of further litigation, (3) the amount of opposition, (4) the reaction of class members to the settlement, (5) the opinion of competent counsel, and (6) the stage of the proceedings and the amount of discovery that was completed.” The court rejected the challenger’s numerous arguments as conflicting, noting that, the challenger claimed the settlement funds would be insufficient to compensate all prospective claimants but also argued excess funds were a significant possibility. On the whole, the panel found the challenger’s arguments insufficient to demonstrate an abuse of discretion by the lower court.