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Conventional wisdom instructs that class actions, which vest control of litigation involving many class members in the hands of a few class representatives, interfere with the exercise of an individual's right to direct her own lawsuit. Class action proponents and opponents alike accept this dogma when they assume that the only defense of group litigation is that its varied benefits outweigh the harms attendant to a loss of individual control over litigation.1 In contrast, this Note argues that the traditional characterization of individualism is inappropriate in the class action context. The important individual interests implicated by group litigation recommend a revision of Rule 23's "opt out" provision so as to make it available to all class members contingent upon a good cause showing.2

Constrained Individualism in Group Litigation: Requiring Class Members to Make a Good Cause Showing before Opting out of a Federal Class Action