How has the court treated the claim of a named plaintiff in a class action?

recognized the duty a named plaintiff owes to the class, and the "flexible character" of mootness in such actions. (Geraghty, supra, 445 U.S. at pp. 400-401, 100 S.Ct. 1202 ; La Sala v. American Sav. & Loan Assn. (1971) 5 Cal.3d 864, 871, 97 Cal.Rptr. 849, 489 P.2d 1113 (La Sala ).) Thus, even when the named plaintiff's claims are moot, courts have under some circumstances applied exceptions to the mootness doctrine to allow the plaintiff to continue prosecuting the suit. Plaintiffs invoke one such exceptionthe "pick

[215 Cal.Rptr.3d 220]

off" exceptionwhich we discuss at length below.