The court of appeals dismissed an appeal. The court held that a member of a class lacked standing to appeal an award of attorney fees to the named plaintiff in a class action that was made pursuant to an order that was independent of the settlement agreement and of the recovery of the class.

Jacob Glasser filed a California state-court class action against Volkswagen of America, Inc. (VW). Under California law, Glasser alleged unfair competition and misrepresentation claims and sought injunctive relief, damages, and statutory attorney fees. VW removed the action. A settlement was reached.