Can a federal court certify a nationwide class action when some of the absent class members would not be able to establish personal jurisdiction over their claims? In any other month, in any other year, a trio of federal appellate court decisions addressing this important issue would draw many eyes. It stands then as a testament to the pandemic-dominated news cycle that March passed with relatively limited comment about the three decisions issued by the D.C. Circuit, the Seventh Circuit, and the Fifth Circuit in Molock v. Whole Foods Market Group, 952 F.3d 293 (D.C. Cir. 2020), Mussat v. IQVIA, Inc., 953 F.3d 441 (7th Cir. 2020), and Cruson v. Jackson National Life Insurance Co., No. 18-40605, — F.3d —, 2020 WL 1443531 (5th Cir. Mar. 25, 2020), respectively.

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