Griffin Industries operates a rendering plant in East Dublin. Cynthia Green, Ann Fennell, Joyce Renfroe, and Richard Kight collectively, the “plaintiffs” are individuals who own or previously owned real property within a two mile radius of the plant. The plaintiffs contend that the plant emits a noxious odor that creates a nuisance and, consequently, lowers their property values. In their complaint, the plaintiffs ask for injunctive relief, compensation for the diminution in value of their property, and punitive damages, and they seek to represent a class of persons they define as “all individuals and non-governmental entities other than Defendants that own or have owned property within two 2 miles of the Laurens County Plant.” The trial court granted the plaintiffs’ motion for class certification, and Griffin Industries appeals. Because we find the trial court’s order on class certification inadequate, we vacate it and remand for the entry of a more detailed order in compliance with OCGA § 9-11-23 f 3. A trial court has broad discretion in deciding whether to allow a case to proceed as a class action, and we will affirm its ruling absent an abuse of discretion.1 OCGA § 9-11-23 sets forth the requirements for certification of a class action, which are: 1 numerosity —that the class is so numerous as to make it impracticable to bring all members before the court; 2 commonality —that there are questions of law and fact common to the class which predominate over any individual questions; 3 typicality —that the claim of the named plaintiff is typical of the claims of the class members; 4 adequacy of representation —that the named plaintiff will adequately represent the interest of the class; and 5 superiority —that a class action is superior to other methods of fairly and efficiently adjudicating the controversy.2 All of these factors should be considered by the trial court in determining whether to certify a class.3
1. Griffin Industries contends that the trial court erred in failing to make required findings of fact in its order certifying the class. When deciding an issue of class certification, the trial court “shall enter a written order addressing whether the factors required by this Code section for certification of a class have been met and specifying the findings of fact and conclusions of law on which the court has based its decision with regard to whether each such factor has been established.”4 Here, the trial court’s order, three and a half pages in length, contains no findings of fact and very brief conclusions of law. The order does not specify the findings of fact and conclusions of law the trial court used in evaluating whether each of the five factors was present, and the trial court did not make any oral findings at the hearing. In fact, the entire analysis of three of the factors consists of one sentence in the order: “the Court finds that the plaintiffs have met the requirements of numerosity, adequacy and typicality.” We thus find that the trial court’s order does not satisfy the requirements of OCGA § 9-11-23 f 3.
