Almost three years ago, the U.S. Court of Appeals for the Eleventh Circuit rocked the class action world with its decision in Johnson v. NPAS Solutions, LLC, finding that class representative awards are barred under 140-year-old Supreme Court precedent. To the surprise of many, the Eleventh Circuit denied the petition for rehearing en banc in 2022, and in April the United States Supreme Court denied certiorari, despite a developing circuit split.