GENERATION CHANGERS CHURCH v. CHURCH MUTUAL INSURANCE COMPANY - Articles

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GENERATION CHANGERS CHURCH v. CHURCH MUTUAL INSURANCE COMPANY

Posted by: Azya Thornton on Feb 23, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: T. Joseph Snodgrass, SNODGRASS LAW LLC, Minneapolis, Minnesota, for Appellant.

Attorneys 2: ARGUED: Ryan A. Strain, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, P.C., Memphis, Tennessee, for Appellee.

Attorneys 3: ON BRIEF: T. Joseph Snodgrass, SNODGRASS LAW LLC, Minneapolis, Minnesota, Erik D. Peterson, ERIK PETERSON LAW OFFICES PSC, Lexington, Kentucky, J. Brandon McWherter, MCWHERTER SCOTT BOBBITT PLC, Brentwood, Tennessee, for Appellant.

Attorneys 4: ON BRIEF: Ryan A. Strain, George T. Lewis, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, P.C., Memphis, Tennessee, Daniel J. Ripper, LUTHER-ANDERSON, PLLP, Chattanooga, Tennessee, for Appellee.

Judge(s): cKEAGUE, GRIFFIN, and MATHIS, Circuit Judges

Court Appealed: United States District Court for the Middle District of Tennessee at Nashville

GRIFFIN, Circuit Judge. A tornado passed through Tennessee, damaging two properties owned by plaintiff Generation Changers Church (GCC). GCC filed a claim with its insurer, defendant Church Mutual Insurance Company (Church Mutual) to cover the damage. Although Church Mutual made a payment on the claim, GCC alleges that Church Mutual improperly calculated the amount. So GCC filed a putative class action on behalf of class members from ten states. The district court certified a class with respect to class members from four states but not the remaining six. It concluded that the unsettled nature of the law in these six states would make a ten-state class prohibitively unwieldy. GCC argues that the district court erred in this respect because it failed to conduct an adequate Erie1 analysis when addressing Federal Rule of Civil Procedure 23(b)(3)’s predominance prong. Church Mutual counters that GCC lacks standing to assert claims on behalf of class members whose injuries arose under state laws other than Tennessee’s. We disagree that GCC lacks standing, and we agree that the district court abused its discretion by not conducting any Erie analysis with respect to five of the states—Kentucky, Ohio, Missouri, Mississippi, and Texas. Accordingly, we vacate in part the order denying, in part, and granting, in part, class certification.

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