certification motion, but before the district court decided the motion. See Wilkerson, 828 F.2d at 121 (“It would seem to us that the principle espoused in Geraghty is applicable whether the particular claim of the proposed class plaintiff is resolved while a class certification motion is pending in the district court (as in the present case) or while an appeal from denial of a class certification motion is pending in the court of appeals (as in Geraghty ).”). Since Wilkerson was decided, the Third Circuit has consistently held that a putative class representative whose claim was mooted after the class certification motion was filed but before the motion was decided is not automatically disqualified from representing a class. See Rosetti v. Shalala, 12 F.3d 1216, 1227-28 (3d Cir.1993) (<HOLDING>); Lusardi v. Xerox Corp., 975 F.2d 964, 982 (3d
holding that the district court did not err in dismissing the named plaintiffs claims on summary judgment before reaching the issue of class certification holding that district court in making class certification decision should avoid focusing on merits of underlying class action holding that district court has discretion under appropriate circumstances to rule on summary judgment motion before addressing pending class certification motion holding that under wilkerson it was error for district court to deny class action certification motion of named plaintiffs whose claims were resolved after filing motion for class certification but before district court decided motion holding that where named plaintiff was employee of class counsel district court did not abuse its discretion by denying class certification