Ohio Federal Court Denies Class Certification in Contract Dispute, Illustrating Strategies For Defeating Similar Claims

The Sixth Circuit’s recent en banc decision in Clippinger v. State Farm Auto. Ins. Co., 173 F.4th 817 (6th Cir. 2026), continues to shape class action litigation involving breach-of-contract claims. In Nichols v. State Farm Mutual Automobile Ins. Co., 2026 WL 2581605 (S.D. Ohio Sept. 1, 2026), the Southern District of Ohio denied class certification in a putative class action challenging the method State Farm used to calculate “actual cash value” payments for totaled vehicles.

The plaintiff sought certification of a class of Ohio State Farm insureds who received total loss compensation between January and November 2021 and whose claims were settled using a valuation that included what plaintiff claimed was a “typical” negotiation adjustment.  The plaintiff’s own alleged underpayment was $512.78. 

The court denied certification based on the Sixth Circuit’s recent en banc decision in Clippinger, which it found to be “on all fours” with the plaintiff’s claims.  In Clippinger, the Sixth Circuit held that similar claims could not be pursued on a classwide basis because determining whether State Farm paid the actual cash value for each lost vehicle required individualized, “plaintiff-by-plaintiff” proof. 

The plaintiff attempted to distinguish Clippinger on the ground that her claims arose under Ohio law, while Clippinger involved Tennessee law.  The court rejected this argument, noting that the Sixth Circuit has recognized that the overarching principles of insurance contract interpretation under Ohio and Tennessee law “are the same.”  

The court also denied certification of the plaintiff’s unjust enrichment claim for the same reason: determining whether State Farm retained more than the policy allowed required an individualized assessment of each vehicle’s value.  And the court noted that Ohio does not recognize a standalone cause of action for breach of the implied covenant of good faith and fair dealing, foreclosing that claim as well. 

For defendants facing class action challenges in breach-of-contract claims, Nichols demonstrates the force of Clippinger’s predominance analysis within the Sixth Circuit. It reinforces that where the central question in a breach of contract claim requires individualized assessments, individualized issues will predominate over common questions, making class treatment inappropriate under Rule 23(b)(3).