Task: Text Completion
Input (English): factual evidence. The insufficiency of the evidence is fatal to the requisite analysis of the Rule 23 criteria that a trial court must conduct before certifying a class action. See Citicorp, 715 So.2d at 204 (requiring that a trial court conduct a rigorous analysis of the certification criteria). In this case, the insufficiency of the evidence is reflected in the conclusory analysis of the Rule 23(a) typicality and adequacy criteria contained in the trial court’s certification order. The order merely recites the requirement of these criteria and summarily concludes that both of these prerequisites are met. Thus, the St. Clair Circuit Court abused its discretion in certifying the class in the Wallace Action. ' See Ex parte American Bankers Life Assurance Co., 715 So.2d 186 (Ala.1997) (<HOLDING>). 2. The Rockett Action The Birmingham Water 
 Holding statements: (A) holding the court was not required to decide the issue of whether the district court properly certified a rule 23b2 class because the court already concluded that the district court appropriately certified the class under rule 23b3 citing authority for the proposition that a court need only find that a class action may be maintained under any of the three subdivisions (B) holding that when a court of appeals has jurisdiction on interlocutory appeal the scope of appellate review is not limited to the precise question certified by the district court because the district courts order not the certified question is brought before the court (C) holding that because no class was certified at the time the individual claims were dismissed the class action was properly dismissed (D) holding that a class could not be certified because the definition made class members impossible to identify prior to individualized factfinding and litigation and thereby failed to satisfy one of the basic requirements for a class action under rule 23 (E) holding that the trial court improperly certified a class because it had not conducted a rigorous analysis of the elements of commonality and typicality
Output (English): (E)