Does a plaintiff have to be decertified as a member of a class as a result of their success at trial?

1 The case of Sirota v. Solitron Devices, 673 F.2d 566 (2d Cir.), cert. denied, --- U.S. ----, 103 S.Ct. 86, 213, 74 L.Ed.2d 80 (1982), is not to the contrary. There the defendants challenged the plaintiff's claim to be a member of the class, after the plaintiff had led the class to victory at trial. The court held that the class need not be decertified at that point, noting that "the class's victory before the jury might be thought to rebut" any argument that the plaintiffs' representation of the class was inadequate. Id. at 572. Even if Sirota is read to hold that a victorious class plaintiff is by the fact of victory proven to be an adequate representative of the class, that logic would not apply when a plaintiff had merely won on an individual claim.